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Add You - Compliance and Regulation: Impacting on the Global Business Community
Fear will jetison you into fight or flight mode. Resistance will try to figure things out. Why? Because fear is a vibration of powerlessness and resistance is a vibration of opposition.On an energetic level, powerlessness feels quite different from opposition. Test it out. Think this thought: fear. How did your body respond to the thought of fear? Did you notice your eyes dilating? Did you experience rapid and shallow breathing? Did your eyes narrow and dart around the room looking for an escape route or assault weapon? Could you feel your body winding-up, getting ready to spring?Now, think this thought: opposition. How did your body respond to that thought? Did you feel your arms crossing protectively in front of your chest? Did you notice your feet spreading apart, taking a wider stance? Could you feel your breath deepening in preparation for a standoff? Think Wyatt Earp at the O.K. Corral.The Voices of Powerlessness and OppositionRun! Go! Command is the voice of powerlessness. Fear expresses itself in short, one-word phrases. That's because the part of the brain that functions when you are in fear is the reptilian brain, the brain stem. The reptilian brain is driven by fear, focuses on survival, and takes over when you feel threatened or endangered.What is holding me back? What am I afraid of? Questioning is the voice of resistance. So are statements such as, "Go ahead; make my day." Resistance expresses
Conflictions in Compliance
Document management systems are challenged when different data in the same document relates to both the Data Protection Act and the Freedom of Information Act, since one is geared for confidentiality, the other for accessibility.
Leading document management systems such as TokOpen, control who can view different parts of a document, meeting the conflicting needs of both pieces of legislation.
In a typical document, such as a Wire Transfer Application form, some of the information falls under the Freedom of Information Act, and other parts of the document are private meaning access must be restricted and audited in accordance with the Data Protection Act. Certain data must not be disclosed to anyone outside the bank as it is private and for internal use only.
Document management software overcomes this problem by hiding the internal information when the document is viewed by someone outside the bank. Users with authorised access are still able to view the whole document.
In the same example, the applicant’s name and address are protected by the Data Protection Act, and should therefore only be seen by the staff members dealing with that client, such as HR or Accounts. Remaining staff do not have access to these specific document details. TokOpen document management software can ensure compliance with this.
Document Management: the Way Forward
The increasingly complex demands of legislation underline the need for businesses to implement document capture and docume
If you ever thought of making and selling your soaps, You must read this article. We'll talk about how to correctly price your soaps. This is very important, as you need to know exactly how much a bar of soap costs you to make. Pricing is extremely important for any business to maximize profit. Why? Simple. If you price your soaps too low - you end up loosing money you should be making. If you price your soaps too high - you loose customers and sales you should have made (because they buy from your competitor, where it's cheaper). Do you see why correct pricing is so important? ;-) So, let's begin. All the numbers below are merely examples. Your numbers will be different: 1. FIXED COSTS: All the costs you have before making one bar of soap, per month: Rent: $150 (one room of your house is used for soap making) Phone: $70 Water: $10 Electricity: $20 Insurance: $20 Equipment (pots, spoons, thermometers, moulds etc.): $30 (let's assume I spend $360 per year in equipment) So, the total for fixed costs is : $300 per month. If you make 1,000 soap bars per month, your fixed cost per bar would be: $300 / 1,000 = $0.3 per bar 2. RAW MATERIALS Let's take a simple soap recipe to make th
The latest compliance standards focus on greater accountability and control in key business processes – most importantly document flows and data management.
There are two central aspects to enforcing compliance:
• The corporate duty of care in enforcing standards
• The need for legal protection in the event of litigation or a dispute
Non-compliance is not an option, companies risk stiff fines and executives can be held personally liable if information is not in order. Therefore, it is important that the business examines all regulations, not just those affecting their specific area of operation, but also generic legislation affecting general business activities.
The consequences of non-compliance are extremely serious; in December 2002 the SEC fined five Wall Street brokerages a total of $8.25m for improperly storing e-mail communications (Forrester Research).
Distributing documents for approval, whether in hard copy or electronic form, raises security issues. Who is authorised to access documents, and what information can they access within them? This is particularly important to ensure compliance with legislation such as the Sarbanes Oxley Act, which applies to US companies and their foreign subsidiaries; and in the UK, the Data Protection Act and the Freedom of Information Act.
Document processing software such as Tokairo’s TokOpen system addresses these challenges and automatically enforces compliance. Every action relating to individual document access is audited, access is limited to specified personnel, and actions they can undertake are also controlled. Software can also restrict access to different information within a document, to different specified users or groups within an organisation.
This ability to allow different information in a document to be seen by different users means that the divergent needs of the Data Protection Act and the Freedom of Information Act can both be met automatically, without the need to make copies of documents.
This flexibility can also extend to the hierarchy of approval based on the value of an invoice. So if a member of staff is not allowed to approve payment of an invoice of over ?500 for example, it can still be checked by them, but then can automatically be escalated to a superior for payment sign-off.
The following are some of the most recent regulations, and the effects they can have on corporate document management strategies:
Sarbanes Oxley Act 2002
This is a key driver of compliant corporate document management systems. In the US non-compliance is now a Federal offence, carrying a penalty of up to 20 years in prison. US subsidiaries in the UK are also required to comply with this legislation. The European Union is expected to introduce similar rulings for member countries.
Under section 302, the CEO and CFO must certify that reports accurately show the company’s financial condition and results. In addition, they must certify that they have established and evaluated internal controls to ensure accurate recording and reporting of performance. Any deficiencies in these controls as well as any fraud at management level must be reported.
Section 404 requires annual reports to detail internal controls that are in place to ensure accurate financial reporting, as well as an assessment of their effectiveness.
This can have a significant impact on a document management system. For example, a company without clear control and visibility of approving invoices for payment could be in breach of the Sarbanes Oxley Act.
Data Protection Act 1998
Regardless of what document management system may be in place, personal information for business use needs to be handled in compliance with the Data Protection Act 1998. A secure document management system such as TokOpen can help with compliance, as it reduces the scope for theft or accidental loss of personal and confidential data. It can also facilitate the execution of valid requests for such data.
The Act enshrines eight principles:
1. Personal data shall be processed fairly and lawfully.
2. It shall be obtained only for specified lawful purposes, and shall not be further processed in any manner incompatible with those purposes.
3. It shall be adequate, relevant and not excessive in relation to the purposes for which it is being processed.
4. It shall be accurate and, where necessary, kept up to date.
5. It shall not be kept for longer than is necessary.
6. It shall be processed in accordance with the rights of data subjects under the Act.
7. Appropriate technical and organisational measures shall be taken to prevent unauthorised or unlawful processing of personal data, and to prevent accidental loss, destruction or damage to personal data.
8. Personal data shall not be transferred to a country or territory outside the EU unless an adequate level of protection for the rights and freedoms of data subjects is ensured.
Freedom of Information Act
This gives people a general right of access to information held by, or on behalf of, public authorities. It is intended to promote a culture of openness and accountability amongst public sector bodies, and to increase public understanding of how public authorities work, why they make the decisions they do, and how they spend public money.
Good document management should be a key objective for all organisations, public and private, in the drive to achieve business efficiency, and ensure that information is easily retrievable and properly documented. As a result of this, public authorities will then be able to comply more easily with legislation that affects them, such as the Freedom of Information Act.
The principles underlying records management – creation, retention, identification and retrieval – apply equally to both electronic and paper media. This means that procedures for e-mail and other information held on shared and personal hard drives have to be as robust and detailed as those for other records.
Conflictions in Compliance
Document management systems are challenged when different data in the same document relates to both the Data Protection Act and the Freedom of Information Act, since one is geared for confidentiality, the other for accessibility.
Leading document management systems such as TokOpen, control who can view different parts of a document, meeting the conflicting needs of both pieces of legislation.
In a typical document, such as a Wire Transfer Application form, some of the information falls under the Freedom of Information Act, and other parts of the document are private meaning access must be restricted and audited in accordance with the Data Protection Act. Certain data must not be disclosed to anyone outside the bank as it is private and for internal use only.
Document management software overcomes this problem by hiding the internal information when the document is viewed by someone outside the bank. Users with authorised access are still able to view the whole document.
In the same example, the applicant’s name and address are protected by the Data Protection Act, and should therefore only be seen by the staff members dealing with that client, such as HR or Accounts. Remaining staff do not have access to these specific document details. TokOpen document management software can ensure compliance with this.
Document Management: the Way Forward
The increasingly complex demands of legislation underline the need for businesses to implement document capture and documen
If an office expects to spend about $50 or more on routine postage in a month, then a postage meter is definitely beneficial. The postal charge is printed by the meter unit of the equipment. In the case of online postage, there are services that permit the customer to download the postage from the Internet and print it directly onto the envelope or labels using the existing printer. This is either software based or integrated with a mini-hardware storage device.The postage meter uses a homogeneous ink for printing the indicia. This ink is formulated by dissolving a coloring material made of a fluorescent toner in a non-volatile blending solution consisting of low molecular weight, fluid, and nonionic surfactants. The surfactants are organic solutions of alcohol or ester and glycols. The consistency of the ink can be altered using viscosity modifiers. All the components of the ink are non-toxic, non-hygroscopic, and do not affect the material on which they are used.The colors of ink used for printing postage meter stamps are red, blue, purple, green, black, orange, and lilac. According to the United States Postal Service (USPS) customer support for mailing standards for meters used in post offices, only tape and red ink furnished by the Postal Service may be used. Post offices are required to use the green ink in meters, while customers should never use red ink. They may use other colors as long as the ink meets the Postal Service’s fluorescent requir
This ability to allow different information in a document to be seen by different users means that the divergent needs of the Data Protection Act and the Freedom of Information Act can both be met automatically, without the need to make copies of documents.
This flexibility can also extend to the hierarchy of approval based on the value of an invoice. So if a member of staff is not allowed to approve payment of an invoice of over ?500 for example, it can still be checked by them, but then can automatically be escalated to a superior for payment sign-off.
The following are some of the most recent regulations, and the effects they can have on corporate document management strategies:
Sarbanes Oxley Act 2002
This is a key driver of compliant corporate document management systems. In the US non-compliance is now a Federal offence, carrying a penalty of up to 20 years in prison. US subsidiaries in the UK are also required to comply with this legislation. The European Union is expected to introduce similar rulings for member countries.
Under section 302, the CEO and CFO must certify that reports accurately show the company’s financial condition and results. In addition, they must certify that they have established and evaluated internal controls to ensure accurate recording and reporting of performance. Any deficiencies in these controls as well as any fraud at management level must be reported.
Section 404 requires annual reports to detail internal controls that are in place to ensure accurate financial reporting, as well as an assessment of their effectiveness.
This can have a significant impact on a document management system. For example, a company without clear control and visibility of approving invoices for payment could be in breach of the Sarbanes Oxley Act.
Data Protection Act 1998
Regardless of what document management system may be in place, personal information for business use needs to be handled in compliance with the Data Protection Act 1998. A secure document management system such as TokOpen can help with compliance, as it reduces the scope for theft or accidental loss of personal and confidential data. It can also facilitate the execution of valid requests for such data.
The Act enshrines eight principles:
1. Personal data shall be processed fairly and lawfully.
2. It shall be obtained only for specified lawful purposes, and shall not be further processed in any manner incompatible with those purposes.
3. It shall be adequate, relevant and not excessive in relation to the purposes for which it is being processed.
4. It shall be accurate and, where necessary, kept up to date.
5. It shall not be kept for longer than is necessary.
6. It shall be processed in accordance with the rights of data subjects under the Act.
7. Appropriate technical and organisational measures shall be taken to prevent unauthorised or unlawful processing of personal data, and to prevent accidental loss, destruction or damage to personal data.
8. Personal data shall not be transferred to a country or territory outside the EU unless an adequate level of protection for the rights and freedoms of data subjects is ensured.
Freedom of Information Act
This gives people a general right of access to information held by, or on behalf of, public authorities. It is intended to promote a culture of openness and accountability amongst public sector bodies, and to increase public understanding of how public authorities work, why they make the decisions they do, and how they spend public money.
Good document management should be a key objective for all organisations, public and private, in the drive to achieve business efficiency, and ensure that information is easily retrievable and properly documented. As a result of this, public authorities will then be able to comply more easily with legislation that affects them, such as the Freedom of Information Act.
The principles underlying records management – creation, retention, identification and retrieval – apply equally to both electronic and paper media. This means that procedures for e-mail and other information held on shared and personal hard drives have to be as robust and detailed as those for other records.
Conflictions in Compliance
Document management systems are challenged when different data in the same document relates to both the Data Protection Act and the Freedom of Information Act, since one is geared for confidentiality, the other for accessibility.
Leading document management systems such as TokOpen, control who can view different parts of a document, meeting the conflicting needs of both pieces of legislation.
In a typical document, such as a Wire Transfer Application form, some of the information falls under the Freedom of Information Act, and other parts of the document are private meaning access must be restricted and audited in accordance with the Data Protection Act. Certain data must not be disclosed to anyone outside the bank as it is private and for internal use only.
Document management software overcomes this problem by hiding the internal information when the document is viewed by someone outside the bank. Users with authorised access are still able to view the whole document.
In the same example, the applicant’s name and address are protected by the Data Protection Act, and should therefore only be seen by the staff members dealing with that client, such as HR or Accounts. Remaining staff do not have access to these specific document details. TokOpen document management software can ensure compliance with this.
Document Management: the Way Forward
The increasingly complex demands of legislation underline the need for businesses to implement document capture and docume
For centuries the four poster bed has been considered the ultimate dream, for practical, status or for romantic reasons. This still seems to be the case today, although wood and plastics are being used to make four poster beds as well as the traditional solid woods.As a business devoted to customer satisfaction, we would like to give our clients the designs that they want, and not make what we want, and expect or hope that they like them, or not as the case may be.The best thing that product manufacturers can have from customers is feedback. It has become clear to me that negative feedback can be as useful, if not more so than positive. Constructive criticism and the reasons for not liking a product can often be more productive than a pat on the back.Many business gurus believe that businesses can grow to be hardly recognisable from how they started within five years, as they develop to meet market demand. Markets change, and it is said that clever businesses should keep up with customer taste. It has also been said that the best businesses anticipate what the customer wants. Others say that cutting edge businesses give the customer what they want, before they even know they want it, and so define fashions.So why do markets change? Why do people stop buying a certain style of furniture that has been fashionable for years? You know that the product is good because the customers that have bought it previously are delighted, and told yo
Section 404 requires annual reports to detail internal controls that are in place to ensure accurate financial reporting, as well as an assessment of their effectiveness.
This can have a significant impact on a document management system. For example, a company without clear control and visibility of approving invoices for payment could be in breach of the Sarbanes Oxley Act.
Data Protection Act 1998
Regardless of what document management system may be in place, personal information for business use needs to be handled in compliance with the Data Protection Act 1998. A secure document management system such as TokOpen can help with compliance, as it reduces the scope for theft or accidental loss of personal and confidential data. It can also facilitate the execution of valid requests for such data.
The Act enshrines eight principles:
1. Personal data shall be processed fairly and lawfully.
2. It shall be obtained only for specified lawful purposes, and shall not be further processed in any manner incompatible with those purposes.
3. It shall be adequate, relevant and not excessive in relation to the purposes for which it is being processed.
4. It shall be accurate and, where necessary, kept up to date.
5. It shall not be kept for longer than is necessary.
6. It shall be processed in accordance with the rights of data subjects under the Act.
7. Appropriate technical and organisational measures shall be taken to prevent unauthorised or unlawful processing of personal data, and to prevent accidental loss, destruction or damage to personal data.
8. Personal data shall not be transferred to a country or territory outside the EU unless an adequate level of protection for the rights and freedoms of data subjects is ensured.
Freedom of Information Act
This gives people a general right of access to information held by, or on behalf of, public authorities. It is intended to promote a culture of openness and accountability amongst public sector bodies, and to increase public understanding of how public authorities work, why they make the decisions they do, and how they spend public money.
Good document management should be a key objective for all organisations, public and private, in the drive to achieve business efficiency, and ensure that information is easily retrievable and properly documented. As a result of this, public authorities will then be able to comply more easily with legislation that affects them, such as the Freedom of Information Act.
The principles underlying records management – creation, retention, identification and retrieval – apply equally to both electronic and paper media. This means that procedures for e-mail and other information held on shared and personal hard drives have to be as robust and detailed as those for other records.
Conflictions in Compliance
Document management systems are challenged when different data in the same document relates to both the Data Protection Act and the Freedom of Information Act, since one is geared for confidentiality, the other for accessibility.
Leading document management systems such as TokOpen, control who can view different parts of a document, meeting the conflicting needs of both pieces of legislation.
In a typical document, such as a Wire Transfer Application form, some of the information falls under the Freedom of Information Act, and other parts of the document are private meaning access must be restricted and audited in accordance with the Data Protection Act. Certain data must not be disclosed to anyone outside the bank as it is private and for internal use only.
Document management software overcomes this problem by hiding the internal information when the document is viewed by someone outside the bank. Users with authorised access are still able to view the whole document.
In the same example, the applicant’s name and address are protected by the Data Protection Act, and should therefore only be seen by the staff members dealing with that client, such as HR or Accounts. Remaining staff do not have access to these specific document details. TokOpen document management software can ensure compliance with this.
Document Management: the Way Forward
The increasingly complex demands of legislation underline the need for businesses to implement document capture and docume
In the history of architecture there has often been an unseen contradiction between what the architect wants to design and what the client wants built. Sometimes an architect will get so wrapped up in his vision and personal aesthetic values that what the client likes and does not like becomes secondary, or is overlooked completely. When this happens the house or building created may win design awards and look beautiful to a trained architectural eye, but the client or people who have to live in it may dislike it intensely. Often the owners or tenants will go back in and change things a second or third time to better suit their aesthetics or purpose.At the root of this problem is the very nature of architecture, to create. An architect is very passionate about the creative artistic aspects of his work. He wants to create something new and different and put himself and his vision into his work. Often, however, the growth and development of an architect involves the painful realization that their unique vision does not usually count for very much. The client, after all, is paying for it and has to live with the house or building long after the architect has finished and gone on to other projects. The architect is there to serve the client and not the other way around.The other professions rarely have this problem. Doctors and lawyers are almost always acknowledged to be the decision makers and authorities in their respective fields. Science a
6. It shall be processed in accordance with the rights of data subjects under the Act.
7. Appropriate technical and organisational measures shall be taken to prevent unauthorised or unlawful processing of personal data, and to prevent accidental loss, destruction or damage to personal data.
8. Personal data shall not be transferred to a country or territory outside the EU unless an adequate level of protection for the rights and freedoms of data subjects is ensured.
Freedom of Information Act
This gives people a general right of access to information held by, or on behalf of, public authorities. It is intended to promote a culture of openness and accountability amongst public sector bodies, and to increase public understanding of how public authorities work, why they make the decisions they do, and how they spend public money.
Good document management should be a key objective for all organisations, public and private, in the drive to achieve business efficiency, and ensure that information is easily retrievable and properly documented. As a result of this, public authorities will then be able to comply more easily with legislation that affects them, such as the Freedom of Information Act.
The principles underlying records management – creation, retention, identification and retrieval – apply equally to both electronic and paper media. This means that procedures for e-mail and other information held on shared and personal hard drives have to be as robust and detailed as those for other records.
Conflictions in Compliance
Document management systems are challenged when different data in the same document relates to both the Data Protection Act and the Freedom of Information Act, since one is geared for confidentiality, the other for accessibility.
Leading document management systems such as TokOpen, control who can view different parts of a document, meeting the conflicting needs of both pieces of legislation.
In a typical document, such as a Wire Transfer Application form, some of the information falls under the Freedom of Information Act, and other parts of the document are private meaning access must be restricted and audited in accordance with the Data Protection Act. Certain data must not be disclosed to anyone outside the bank as it is private and for internal use only.
Document management software overcomes this problem by hiding the internal information when the document is viewed by someone outside the bank. Users with authorised access are still able to view the whole document.
In the same example, the applicant’s name and address are protected by the Data Protection Act, and should therefore only be seen by the staff members dealing with that client, such as HR or Accounts. Remaining staff do not have access to these specific document details. TokOpen document management software can ensure compliance with this.
Document Management: the Way Forward
The increasingly complex demands of legislation underline the need for businesses to implement document capture and docume
Medical billing can be a real nightmare. No wonder the turnover with medical billers is so great. Between the number of regulations, pile of forms and tons of red tape, it's enough to make anybody crazy. One of the worst culprits is the DMEPOS CMN, or the GU0 record, which is used for electronic transmission of claims using NSF 3.01 specifications. In this installment, we'll be covering the GU0 record, picking up with field number 8.GU0 field 8, positions 32 - 33, is the HCPCS modifier. The HCPCS modifiers are one of the big reasons that medical billers lose their minds so quickly. Having to keep track of which modifier goes with what month can be a real pain in the backside. Fortunately, most electronic billing software packages take care of this for you. This field is used to tell the carrier which month of billing you're in for the item or service in question.GU0 field 9, position 34, is the warranty reply field. This field tells the carrier if the item being billed for this CMN is under warranty or not. If it is, the field is transmitted as a Y. If it isn't, it is transmitted as an N. If this doesn't apply, then the field is transmitted as a D.GU0 field 10, positions 35 - 36, is the warranty length. If the item is under warranty, as designated by field number 9, then this field tells the carrier what the warranty period is in months.GU0 field 11, position 37, is the warranty type. This field tells the carrier what type
Conflictions in Compliance
Document management systems are challenged when different data in the same document relates to both the Data Protection Act and the Freedom of Information Act, since one is geared for confidentiality, the other for accessibility.
Leading document management systems such as TokOpen, control who can view different parts of a document, meeting the conflicting needs of both pieces of legislation.
In a typical document, such as a Wire Transfer Application form, some of the information falls under the Freedom of Information Act, and other parts of the document are private meaning access must be restricted and audited in accordance with the Data Protection Act. Certain data must not be disclosed to anyone outside the bank as it is private and for internal use only.
Document management software overcomes this problem by hiding the internal information when the document is viewed by someone outside the bank. Users with authorised access are still able to view the whole document.
In the same example, the applicant’s name and address are protected by the Data Protection Act, and should therefore only be seen by the staff members dealing with that client, such as HR or Accounts. Remaining staff do not have access to these specific document details. TokOpen document management software can ensure compliance with this.
Document Management: the Way Forward
The increasingly complex demands of legislation underline the need for businesses to implement document capture and document management systems. However, even though a document management system is an important component, alone it will not ensure compliance. A wider view is needed to ensure businesses maintain their compliance with changing legislation.
In a court of law, the judge will consider the evidence based on several criteria:
• Are procedures clear and consistent, with a requirement to document procedures? This is often referred to as a document policy.
• Are the procedures enforced? This is a shared responsibility between management and the selected document management system's access and privilege controls.
• Can the claims be substantiated? This relies heavily on the document management system’s audit trail.
Compiling a Document Policy
After establishing which regulations have to be complied with, a document policy is required covering the following:
o Scope of information covered
o Security classifications
o Storage media
o File format and version control
o Standards (compliance and regulations)
o Retention and destruction
o Responsibilities
A document policy defines how information is stored, and is therefore central to ensuring compliance. It should serve these main purposes:
o Ensure everyone knows what they can do
o Define the business practice at the time
o Demonstrate why a given action was undertaken, e.g. explains why a document was destroyed
o Reinforce documents’ evidential weight
o Help authenticate documents to increase legal weighting
o Improve the court’s view of the evidence presented
Consideration also needs to be given to how long documents should be stored. This depends on the type of document and industry-specific regulations.
This raises an interesting question. What is the legal position if the original document is electronic? This can best be answered in three steps.
• Civil Evidence Act 1995
o Authenticated copies will be accepted with equal weighting to the original
o Later revisions are given greater weight than superseded revisions
• Admissibility
o Does the court accept this evidence?
o With what weight?
• Appropriate procedures must be followed if documents are to be taken to court
Therefore, when considering compliance, the legal weight given to a document also needs to be taken into account. In addition to ensuring that documents and information are managed in accordance with compliance legislation, document management software also plays a key role in ensuring that optimised legal weighting is given to documents, should they be presented in a court.
Improving documents’ legal weighting depends on three key factors:
• Information management
o System management (duty of care, audits, etc.)
o Operational issues (good management practice)
• Legal issues
o General (e.g. Data Protection Act, invoice storage, etc.)
o Industry-specific (compliance/regulations etc.)
o Organisation-specific (internal regulations etc.)
• Need for clearance permissions
Companies therefore have a duty of care responsibility to ensure they are compliant with legislation. This is best described as information security and can be summarised with the following questions:
• Can a court be assured that information (evidence) has not been inadvertently or maliciously altered, or some of it lost?
o i.e. due care has been taken of the data
• Basic criteria can be met
o Confidentiality (who has had access?)
o Integrity (is it reliable?)
o Availability (can it be retrieved?)
Summary
Ensuring compliance with legislation is a responsibility shared between:
• The staff, following clearly defined document procedures
• The management enforcing these procedures
• The document management system policing and enforcing duty of care responsibilities
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