Cecelia Jefferson discusses the unintended compliance risks of implementing technology in many different business contexts. When seeking to close compliance gaps with technology, it is critical that compliance professionals dig deeper into the problems that the technology may create in real life. For example:
• For liquor stores, if drivers’ licenses can be scanned to ensure all purchasers’ IDs are checked, what privacy and security problems does collecting driver’s license information create?
• How difficult is the new system to train across large numbers of employees?
• Do employees face this compliance issue every day or rarely? How does this impact the effectiveness of the proposed solution?
• For hospitals, if the pharmacy is automated, what happens if the computer goes down? Is there a manual backup?
• Which compliance issues are discoverable by the general public, including regulators, and how does this exposure impact the decision to devote resources to the solution?
• Are the systems flexible enough to be changed if regulators change their interpretation of the law or prioritization of enforcement?
• How do the systems interact with a continually changing enforcement environment and changing laws?
• Is the issue so closely intertwined with the company’s brand that the risk of any noncompliance can be devastating?
Everybody has the intention of being committed to compliance, but when resources need to be devoted to compliance, the company’s true commitment comes into focus.
Cecelia Jefferson is a strategic, multi-talented compliance executive with extensive and diversified legal, compliance, and governance experience. She has worked for almost two decades in compliance and government and as an attorney in the state of Florida. Cecelia is the former Director of Alcohol, Tobacco, and Firearms Compliance at Walmart and has served as the Assistant General Counsel for the Florida Agency for Health Care Administration, and she has held several other roles in state regulation, enforcement, and consumer protection.
Cecelia Jefferson’s email firstname.lastname@example.org
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