School Policy Implementation – A Journey or a Destination? (Part Two)
This is the second part of a two part series on policy implementation in schools. Part one highlighted the myths of policy management and implementation, and proposed some key measurements for a school to determine its success in implementing its policies. Part two provides practical considerations for a school to consider in improving the implementation of its policies and procedures framework.
Measurements of success in terms of policy implementation (as discussed in our previous article) do provide a helpful overview for schools on how they can improve their approach to policy implementation and management. But practically, changing a school’s approach to policy implementation and management is likely to be quite difficult without a clear change management process in place. It also depends on how ingrained a school’s approach to policies and procedures is, and what its culture of compliance has been historically.
There are many methods that schools can pursue to implement policies in an effective way, and the success of these methods will depend on the particular school. That being said, here are a few practical suggestions for schools to consider pursuing.
A Risk Based Approach to Compliance
Take a risk based approach to policy compliance. This is the approach recommended by the International and Australian Standard Compliance Management Systems Guidelines (AS/ISO 19600:2015). The Standard includes a ‘risk based approach to compliance’ which mandates that a compliance risk assessment (i.e. the process of identifying and evaluating compliance risks, and implementing appropriate controls) constitutes the basis for the implementation of a compliance management system in an organisation.
Ask yourself: what is your risk profile when it comes to compliance? The ‘great big list’ approach to compliance obligations will lead to certain failure as a school can only determine its compliance requirements by properly understanding its risk profile.
The Importance of Developing a Culture of Compliance
Perhaps the most difficult, but also the most important, task for schools is to embed compliance in the school culture. AS/ISO 19600:2015 emphasises compliance as being a concept that should be ‘embedded’ in the culture of an organisation and ‘integrated with an organisation’s governance, financial, risk, environmental and health and safety management processes and its operational requirements and procedures’.
It is important for schools to consider the current state of their organisational compliance culture. According to Michael D. Watkins, professor at IMD, culture is a “form of protection” that results from situation pressure, in order to prevent “wrong thinking” and “wrong people” from entering a school in the first place. This characteristic means that organisational culture functions similarly to the human immune system, which prevents viruses and bacteria from infecting and damaging the body. This characteristic of culture may preserve its longevity, but it may mean that a school will be resistant to change, even if the change is positive.
The importance of an open culture is regularly stressed by regulators, most recently by the Royal Commission into Institutional Responses to Child Sexual Abuse (Royal Commission). A report prepared for the Royal Commission by Professor Eileen Munro and Dr Sheila Fish, stated that organisations that achieve a high safety level for children are shown to share a fundamental belief that mistakes will happen and their goal is to spot them quickly: “they encourage an open culture where people can discuss difficult judgements and report mistakes so that the organisation can learn from them.”
Policy Compliance Must be Part of a GRC Framework
Compliance does not operate in a vacuum. It crosses all functions and disciplines within a school. The practical functionality of compliance comes from its role as a key component of the (AS/ISO 19600:2015) (GRC) trilogy. Policy compliance does not work effectively without a proper governance framework and of course, compliance is an important component in school risk management.
Don’t Underestimate the Importance of Leadership and Commitment.
A top-down demonstrated commitment to compliance and to a compliance culture is vital.
Having said that, it takes the whole school to make compliance work. All staff members have a role to play with respect to implementing a Compliance Program, and while their role will depend on their position within the school, each is important. Leaders that delegate compliance to a Compliance Manager can unwittingly make the top-down commitment less visible!
Make it Easy for People to Find Out What to Do
It is crucial for a school to make it easy for staff to find policies that are relevant to them, engage in staff learning regarding policies and to keep records of staff training.
Requiring staff to read a large staff handbook or a slab of paper-based policies is not nearly as effective as utilising online learning systems which break up learning into bite sized chunks that can be accessed at times convenient to the learner via a range of devices. Remember we are talking about the next generation of teachers who are very tech savvy and want to switch from one activity to the next in a seamless way.
A browser-based policy management approach with text searchable features makes it easy for staff to find out what is expected of them. Most people want to ‘do the right thing’ and making it easy to find out what to do is important.
Understand the Importance of Change Management
Professor John Kotter in his work on managing change provides an eight step change management model. The first six steps, adapted for the school environment are:
1. Establish a sense of urgency – work out what they are and leverage the catalysts for change in your school.
2. Form a powerful coalition – assemble a group with enough power to lead the change effort within your school. The key here is to make sure school leaders do not delegate change management activities to staff without sufficient authority to drive the change.
3. Create a Vision – Create a vision to help direct the change effort and strategies for achieving that vision.
4. Communicating the Vision – communicate the new vision and strategies and lead by example. What are the best ways to communicate a change to your policy and compliance systems in your school?
5. Empowering others to act on the vision – removing obstacles to change in your school such as current systems or governance structures.
6. Planning for and creating short term wins – Ensure you can show some change as soon as possible and highlight and celebrate the change. Actually plan for a short term win and then highlight it.
A Journey Not a Destination So Get Started
No organisation is ever fully compliant. A risk-based approach to compliance is therefore a very helpful concept. Organisations are always working towards greater compliance. The most important thing is for your school to get started on improving its policy management and implementation approaches, lest you become a case study of the dangers of non-compliance.
For more information related to this topic see the School Governance paper by David Griffiths, Managing Director of CompliSpace: Challenges Faced-by-Non-Government Schools in Complying with a Complex Matrix of Ever Changing Laws Regulations and Regulatory-Guidance.
About the Author
Jonathan Oliver is a Senior Business Consultant at CompliSpace. He can be contacted here.