A foundational piece to an Ethics and Compliance program is the ability to gather, track and report on disclosures of conflicts of interest across both internal employees, leadership, board members, and even in some use cases third parties. 

The OneTrust Disclosures Management product provides a streamlined experience from the moment an employee discloses information to your compliance team’s assessments of employee risk, and through the reporting that helps refine your overall program. OneTrust’s Ethics & Compliance product team has added capabilities and enhancements to the Disclosures product that are now available to the general public. 

Data redaction to ensure employee data privacy

With any data collection, especially personally identifiable information or PII, there comes a responsibility to steward that data securely with a privacy-first lens. Organizations are seeing more scrutiny on how they manage  customer or third-party data as well as employee data. 

Data redaction for disclosures is the answer to that call for thoughtful employee data privacy and stewardship. 

Customers can now easily redact personally identifiable information in disclosure forms. Use cases can include employee termination or critical compliance with various global data retention schedules.  

Streamline and proactively manage open disclosures

Compliance teams tend to rely on disclosure forms as living documents that help proactively mitigate employee risk and should be reviewed periodically by the employees who submit them for accuracy. 

With OneTrust Disclosure Management, this is a streamlined process. While the year-over-year functionality has been available in the tool, the enhancements provide better resource utilization and a better user experience. This includes the ability to de-activate and activate previously submitted forms if the employee leaves the company, or the disclosure is no longer true or relevant. All previously submitted forms come auto populated with the employee’s most recent answers. It's now easier than ever to customize your disclosures and meet your employees where they are. This functionality is available to all current disclosure customers. 

Review or update existing disclosures before submission

Another enhancement featured in the tool is Disclosure Questionnaire Defensibility. With that same new year-over-year functionality and pre-populated answers from previous submissions comes the risk that employees will not review previous submissions in detail, leaving your organization open to unknown risk. In the event of an audit, this can cause questions of authenticity. With Disclosure Defensibility compliance teams can now ensure employees have reviewed or updated existing disclosures before they submit the questionnaire. Employees are guided to review previous submissions to determine if they need to make updates, so even if nothing has changed, there is no ambiguity to whether the information is accurate.

Incorporate HR data into disclosure workflows

HR data can provide incredible insight and automation into how compliance teams role out programs, send campaigns, and mitigate employee risk. Disclosure teams can pinpoint specific teams, locations, roles, and seniority to roll out targeted disclosure assignments or campaigns around disclosure programs that ultimately save time on analysis and approvals of submitted questionaries. 

Workflow routing can also help teams become more efficient with conditional approver workflows which streamline approvals when system controls identify what needs human review.  Targeted employee outreach via workflow routing or in employee engagement campaigns leads to less manual work so your team can focus on more strategic and impactful initiatives. 

On the horizon: Gifts, Travel, and Entertainment

Looking ahead, the Disclosures tool will soon incorporate capabilities for Gifts, Travel, and Entertainment (GT&E). 

GT&E can be an incredibly complex problem that customers face when looking to implement a best-in-class disclosures program. Disclosing information around these types of potential conflicts needs to be proactively managed and pre-approved to be compliant with many regulations related to financial disclosure, anti-bribery, and anti-corruption. While specialized GT&E functionality is on the horizon, OneTrust already supports basic gift registries and automation.  

Future capabilities for more sophisticated gifts, travel, and entertainment programs will include recipient tracking across individuals, organization-wide, gift giving, and gifts to multiple people. There will be warning signals that alert when gifts exceed the acceptable amount or when a gift is breaching an organization’s policy. Jurisdictional thresholds across the globe will be incorporated along with multiple currencies and currency conversion.  

Disclosure management is  an increasingly important part of any well-rounded Ethics & Compliance program. Global regulations expect organizations to proactively monitor conflicts of interest and act as watchdogs for internal corruption or any level of bribery, whether it be their employees taking or extending bribes. 

With OneTrust’s Disclosure Management tool, compliance teams can save time and resources by automating their program, proactively uncover and mitigate employee risk, and become a true revenue protector for their organization. 

Learn more about these capabilities and how they operate in real time. Sign up for our upcoming webinar, From Reactive to Proactive: Transforming Your Ethics & Compliance Program.