Policy and Procedure

A policy sets out bindingly what is to apply and who is responsible for it. A procedure describes how an activity runs in detail. Both sit in a hierarchy below the top-level policy issued by management and above the work instructions. Drawing the line cleanly determines how often a document has to be re-approved.

GRCLast reviewed:

The four levels

LevelAnswersAudienceApproved byTrigger for change
Top-level policyWhy, and to what standardThe whole organisationTop managementRarely, on strategic change
PolicyWhat applies, who is responsible, which requirements are bindingThe roles affectedTop management or a designated functionChanged requirements
ProcedureHow the flow runs, with steps, responsibilities and decision pointsThe roles performing itProcess ownerProcess changes
Work instruction and formWith what, and to what result, a single activity is performedThe performing unitSubject matter ownerOften, for instance on a change of tool

Below these levels sit the records: the evidence that work was actually done this way.

A note on vocabulary, because it causes trouble in bilingual documentation sets. English uses "policy" for both of the top two levels: the single overarching policy top management signs, and the topic policies derived from it. German separates them as Leitlinie and Richtlinie. Where a group works in both languages, decide which English word carries which level and hold to it. Otherwise the approval authority for a document becomes a matter of opinion.

The practical value of the separation

Put tool names and click paths in a policy, and the policy has to be re-approved on every change of tool, in case of doubt by top management. Put the requirement in the policy and the click path in the work instruction, and only the lower document changes. That is not formalism; it is the difference between a maintained rulebook and an outdated one.

As a rule of thumb: a policy should survive a change of tool. A procedure should survive a change of staff.

What belongs in every policy

Purpose, scope, audience, the binding requirements, roles and responsibilities, the procedure for exceptions, references to co-applicable documents, and a header carrying version, date, approval, the responsible unit and the date of the next review.

The item most often missing is the exception procedure. Without a governed exception, either a silent breach arises that nobody documents, or a blockage arises that holds the business up. A good provision names the deciding authority, the time limit, and the documentation of the reasoning.

Control of documented information

The ISO management system standards require, in clause 7.5, that documented information is appropriately identified, reviewed, approved, distributed and protected against unintended alteration, and that obsolete versions are identifiable. That means a single binding source instead of copies on drives and in mailboxes, a version history, a traceable approval, controlled access, and an orderly withdrawal of superseded documents.

Approval alone does not create bindingness

An approved document nobody knows about has no effect. What it takes is active announcement rather than quiet filing, training on material changes, a documented acknowledgement where direct obligations for employees are created, and a check of actual application in the internal audit. Where a rule touches the conduct or performance of employees, co-determination rights may apply; participation should be clarified early.

How a rulebook goes stale

  • The policy describes a tool and goes stale with it.
  • The procedure has no named owner.
  • Two documents govern the same matter inconsistently.
  • A document has applied unchanged for years and has never been reviewed.
  • The rulebook grows without superseded versions being withdrawn.
  • Exceptions are granted orally and recorded nowhere.
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