Insights

I have argued for years that GRC is not ultimately about maintaining collections of risks, controls, policies, issues, audits, obligations, and assessments. All of these are important components of GRC, but none of them is the destination. Governance establishes direction and enables reliable decision-making. Risk management addresses uncertainty in achieving objectives. Compliance ensures that the organization acts with integrity in meeting its obligations and commitments while pursuing those objectives. What ultimately matters, then, is not the volume of governance activity an organization can demonstrate, but whether it can reliably make decisions, achieve objectives, address uncertainty, and act with integrity.

A critical system goes down, and the operations team needs an administrator inside it immediately. Privileged access, however, requires approval, and the designated approver is unavailable. A change may restore the system, but normal procedure requires testing before anything reaches production. Meanwhile, the recovery clock is running.

There is a strange rule in compliance: when something goes wrong, organizations add a control. A regulator raises a concern? Add a control. An auditor finds a weakness? Add another. A cyberattack happens? Add three. A new framework arrives? Someone opens a spreadsheet. Nobody ever gets celebrated for deleting one.

A few weeks ago, I wrote about a question that had followed me from a computer room in Milwaukee thirty years ago into today's conversations about agentic AI, "Where is the big red button?"

For a long time, seeing someone or hearing their voice gave us a reasonable level of confidence that we knew who we were dealing with. If your manager called, you recognized their voice. If a senior executive joined a video meeting, you could see them on the screen. There was usually little reason to question whether the person you were speaking to was actually who they claimed to be.

Corporate America has found a new way to signal its ambition: hiring software. Companies are giving artificial intelligence (AI) agents names, titles, and places on the organizational chart, and press releases celebrate the arrival of the “first AI employee” as though a person had walked through the door. According to MIT Technology Review’s James O’Donnell, nearly a third of the 1,261 managers surveyed in a recent Boston University study said their companies already frame AI agents as employees, and 23 percent list them on org charts.

Article 30 of the GDPR requires organizations to maintain a record of processing activities, a running account of what personal data is collected, why, where it goes, and how long it is kept. In the spring of 2018, producing this record was urgent work, done under outside counsel's supervision and briefed to the board. Seven years on, in a great many organizations, it is a spreadsheet that gets copied forward each quarter by whoever currently holds the job, edited just enough to survive an audit, verified by almost no one, because verifying it would mean re-establishing, line by line, whether the data flows it describes still exist in the form it claims they do. Vendor relationships lapse and the row survives them. Systems get decommissioned and the row survives that too. The record persists not because it is accurate but because it is inherited, and inheriting a document is a different act from understanding it.