M1.1 MONITOR CONTROLS, POLICIES & PROCEDURES
Conduct real-time, ongoing monitoring of the program to ensure that it is operating within defined tolerances.


Ongoing monitoring activities are generally performed as part of the recurring operational activity of the entity. They are distinguished from preventative and control activities in that they involve a level of analysis, review and focus on relationships and inconsistencies of underlying processes. For example, the routine tracking of students who took training and how that compares with the plan would be considered a control activity. The weekly review of how many students completed training and comparing that information with the certificates that were granted would be considered a monitoring activity.

Where appropriate, monitoring activities should be conducted in whole or in part by personnel who are not involved in conducting the day-to-day activity under evaluation. This may include supervisors or peer personnel who have a tangential relationship to the activities under evaluation.

Typical monitoring techniques include:
> reconciliation
> cross-referencing
> monitoring and analyzing logs
Standards & Guidance
    M1.1.S02
  • Ensure that the organization's compliance and ethics program assessment is coordinated with other assessments conducted by the organization.
    E2.2.S02
  • Ensure that the compliance and ethics program is followed, including monitoring and auditing to detect criminal conduct
Core Practices
    M1.1.101
  • Define the assessment process(es) used to assure compliance
    M1.1.102
  • For each control, define ongoing monitoring activities that ensure that the program is operating within defined tolerances
    M1.1.103
  • Define procedures and accountability for exceptions
    M1.1.104
  • Define thresholds for immediately remediating the system or escalating the incident of noncompliance to a more sophisticated investigation, resolution and remediation
Additional Practices
    M1.1.201
  • For each monitoring activity, consider using technology to automate monitoring
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