What to Do About the Period Before

A rule changed in March and the configuration changed in November. Between those dates the organisation operated on the old rule: rotas built, averages computed, records kept.

The workflow in “What to Do About the Period Before” becomes more dependable when scheduled work, actual time and later corrections can be distinguished. For teams exploring remote desktop monitoring software, Monitask resources for remote desktop monitoring software can provide operational context, while policy ownership, employee explanation and consequential decisions remain with accountable people.

Nothing can be done about the hours that were worked. What can be done is to establish the extent, decide what follows, and record it — and the instinct to do none of those is the thing that turns a lag into a problem.

For an independent reference relevant to “What to Do About the Period Before”, consult the CERT insider-risk research. Use it to challenge assumptions about working time, privacy, recordkeeping and exception handling against the organisation’s real operating model.

Establishing the extent

Three questions. Which populations were affected. For how long. And how many people would have been outside the new rule during that period.

The third is a calculation on data the organisation already has: apply the new rule retrospectively to the period and count. It takes an afternoon and it converts an uncomfortable unknown into a number.

Frequently the number is small. A rest requirement that rose by an hour affects only the patterns that were close to the old minimum, which may be one department.

What usually follows

For most changes, nothing beyond a record. The period has passed, the hours were worked, and there is no mechanism to undo it.

Where the change created an entitlement — compensatory rest, a payment, a notification that should have been made — that entitlement may still be owed, and establishing whether it is belongs with whoever advises in that country.

Where a notification deadline was missed, late notification is usually better than none and that is also an advice question.

The record to make

Date the change took effect, date the organisation became aware, date it was implemented, the populations affected, the extent as calculated, what was decided and by whom.

One page. It is the difference between an organisation that found a gap and dealt with it and one that has a gap, and the difference is visible to anybody reading the file afterwards.

Telling the people affected

Where something is owed, obviously. Where nothing is owed, the question is harder and the answer is usually still yes for anybody who would reasonably expect to know.

A short factual note — a rule changed, we implemented it late, here is what that meant for you, here is what we are doing — is almost always better received than the alternative, which is that somebody finds out another way.

It also removes the possibility of the gap being characterised later as concealed.

What not to do

Do not recompute history to make the figures fit the new rule. The records say what they say, and a retrospective recalculation that makes an old period look compliant is a false record.

Do not quietly implement and hope. The implementation date is visible in the system's own audit trail and the effective date is public.

And do not treat the length of the lag as the thing to minimise in the telling. Eight months reported accurately is a better position than three months reported defensively.

Preventing the next one

The lag is a process measurement, and the fix is in the process rather than in anybody's diligence.

After each late implementation, look at which of the four handoffs consumed the time — receiving, assessing, deciding, implementing — and fix that one. Most organisations find the same handoff consuming the time every time, which makes it a single piece of work rather than a general exhortation to be quicker.

The backlog question

An organisation running this exercise for the first time may find several past changes implemented late or not at all.

Work them in order of extent rather than in order of discovery, record each the same way, and set a date by which the backlog is cleared. A dated clearance plan is a reasonable position; an open-ended review is not, and it is what these exercises turn into when nobody sets the date.

Saying how you found it

A record that notes how the gap came to light — an annual check, a local report, an adviser's question — is worth more than one that simply states the dates.

It shows whether the organisation's own process found it, which is the question behind the question whenever these things are reviewed.

It also tends to be the most useful line for improving the process, because a gap found by an adviser rather than by the annual check says something specific about what the check is missing.

The change that improved things

Not every late implementation leaves an exposure. Where a rule became less restrictive, the period before was computed on a stricter basis, which is not a breach of anything.

Those are worth recording with the same discipline, because the record of how changes are handled should not consist only of the uncomfortable ones.

It also prevents an unnecessary remediation exercise, which does happen: an organisation discovering a lag and assuming exposure without checking which direction the change ran.