GRC-C01 / GOVERNANCEILLUSTRATIVE
Check authority before a significant commitment
Risk addressed: A commitment is approved without the right authority, supporting evidence or clear conditions.
- How it could operate
- In this example, the proposed decision is routed to an authorised approver, who checks the options, evidence and approval conditions before recording the decision.
- Evidence to look for
- The delegated-authority record applicable on the decision date.
- The decision paper and supporting records available to the approver.
- The approved decision, reasons, conditions and follow-up owner.
Suggested test, trigger & failure indicator
Test: Select significant commitments from a defined period; compare the approval date and decision-maker with the authority record, then trace any conditions to follow-up evidence. Record selection limits.
Suggested operating trigger: a commitment reaches an agreed approval threshold or falls outside an existing delegation.
Possible failure: The commitment predates approval, the approver lacks recorded authority or an approval condition has no follow-up.
Example only. No test has been performed and no assurance is given.
GRC-C02 / GOVERNANCEILLUSTRATIVE
Record interests and participation in a decision
Risk addressed: A relevant interest is overlooked or the record does not explain how participation and conflicts were handled.
- How it could operate
- In this example, participants declare relevant interests before a significant decision; the chair or responsible reviewer checks the applicable process and records how participation is handled.
- Evidence to look for
- The interest declaration relevant to the decision.
- The applicable governance procedure and any advice obtained.
- Minutes recording the interest, treatment of participation and decision.
Suggested test, trigger & failure indicator
Test: Choose decisions involving a declared interest; compare declarations, attendance and minutes with the applicable process. Identify omissions without inferring that absence of a declaration proves absence of a conflict.
Suggested operating trigger: a significant decision, a newly disclosed interest or a change affecting a previously recorded interest.
Possible failure: A disclosed interest is absent from the decision record or the treatment of participation cannot be explained.
Example only. No test has been performed and no assurance is given.
GRC-C03 / GOVERNANCEILLUSTRATIVE
Review a policy against the work it governs
Risk addressed: An approved policy becomes detached from the process staff actually use.
- How it could operate
- In this example, the policy owner checks a current procedure and a real or clearly marked practice case, proposes corrections and obtains approval before communicating the revised version.
- Evidence to look for
- The policy register showing owner, approver and current version.
- Walkthrough notes identifying where instructions matched or differed from practice.
- The approved revision and evidence that affected staff received and understood the changes.
Suggested test, trigger & failure indicator
Test: Choose a policy changed during the review period; trace one substantive change from the identified problem through approval, communication and subsequent use. Keep document and implementation findings separate.
Suggested review trigger: a service or system change, repeated workaround, incident finding or the organisation's chosen review point.
Possible failure: Staff use a superseded version or the revised instruction still cannot be followed in the actual process.
Example only. No test has been performed and no assurance is given.
GRC-C04 / GOVERNANCEILLUSTRATIVE
Escalate a risk-limit exception
Risk addressed: Exposure outside an agreed limit continues without an informed and authorised decision.
- How it could operate
- In this example, the risk owner flags an agreed threshold breach; the authorised decision-maker records the response, any temporary safeguards and the scope and expiry of an accepted exception.
- Evidence to look for
- The approved limit and escalation authority in use at the time.
- The exception request with exposure, assumptions and proposed safeguards.
- The decision, conditions, expiry and evidence of follow-up.
Suggested test, trigger & failure indicator
Test: Select recorded threshold breaches and exceptions; compare the response with the escalation rule and inspect whether conditions and expiry were reviewed. Record breaches found outside the exception log.
Suggested operating trigger: an agreed limit is approached or exceeded, or an exception is nearing expiry.
Possible failure: An exception expires without review or the limit is retrospectively increased without a recorded decision.
Example only. No test has been performed and no assurance is given.
GRC-C05 / GOVERNANCEILLUSTRATIVE
Bring evidence gaps into the board review
Risk addressed: Decision-makers receive a reassuring summary that conceals untested controls or unresolved material weaknesses.
- How it could operate
- In this example, the review coordinator links material risks to dated control evidence, identifies gaps and exceptions, and brings specific decisions to the board or accountable owner.
- Evidence to look for
- The review scope and rationale for the risks and controls selected.
- A board pack linked to test periods, findings and evidence limitations.
- Minutes recording challenge, decisions and follow-up on unresolved weaknesses.
Suggested test, trigger & failure indicator
Test: Choose a material risk from a board pack; trace its reported status to underlying evidence and compare unresolved findings with the decisions and actions recorded. Note untested coverage.
Suggested review trigger: the agreed oversight meeting, a material control failure or a significant change in exposure.
Possible failure: A favourable status has no traceable evidence or a material unresolved finding is omitted from the decision pack.
Example only. No test has been performed and no assurance is given.
GRC-C06 / GOVERNANCEILLUSTRATIVE
Separate implementation from verified action closure
Risk addressed: An issue is closed on the action owner's assertion before the agreed outcome has been checked.
- How it could operate
- In this example, the action owner submits completion evidence; a designated reviewer compares it with agreed criteria and records the retest result before approving closure.
- Evidence to look for
- The finding, agreed action and completion criteria.
- The action owner's implementation evidence and submission date.
- The review or retest record, limitations and closure decision.
Suggested test, trigger & failure indicator
Test: Select actions marked complete, including consequential findings; inspect whether the evidence demonstrates the agreed outcome and whether retesting occurred before closure. Identify claimed fixes awaiting verification.
Suggested operating trigger: an owner requests closure or a previously completed action fails in use.
Possible failure: A closed action contains only an assurance statement, or the cited retest happened before the change was implemented.
Example only. No test has been performed and no assurance is given.
GRC-C07 / RISKILLUSTRATIVE
Review a critical supplier before commitment
Risk addressed: The organisation relies on a supplier without understanding service dependencies, assurance limits or exit obstacles.
- How it could operate
- In this example, the service owner assesses the dependency, checks evidence for the actual service and submits unresolved gaps and approval conditions before selection or renewal.
- Evidence to look for
- The supplier entity, service scope, access and dependency record.
- Assurance evidence with its coverage, dates, exclusions and open findings identified.
- The approval decision, monitoring conditions and exit assumptions requiring validation.
Suggested test, trigger & failure indicator
Test: Select a critical supplier added or renewed during the period; trace a material assurance claim to its source and inspect whether approval conditions were resolved or explicitly accepted.
Suggested operating trigger: selection, renewal, a material subcontractor change or repeated service failure.
Possible failure: The assurance covers a different service or an unresolved dependency is missing from the approval decision.
Example only. No test has been performed and no assurance is given.
GRC-C08 / RISKILLUSTRATIVE
Compare system access with current responsibilities
Risk addressed: People retain access that no longer matches their role or the service's approved arrangements.
- How it could operate
- In this example, the system owner compares current access with authorised responsibilities, obtains decisions on discrepancies and records the resulting access changes.
- Evidence to look for
- A dated access listing for the system and review scope.
- The authorised role or access requests used for comparison.
- Recorded discrepancies, approval decisions and confirmation of changes made.
Suggested test, trigger & failure indicator
Test: Choose access changes and a sample of current accounts, including changed roles; compare authorisation with the access actually present and trace discrepancies to resolution. State coverage limitations.
Suggested operating trigger: a role, supplier or system-access change and the organisation's chosen access-review cycle.
Possible failure: An account's access cannot be connected to a current authorised responsibility or a recorded removal remains unapplied.
Example only. No test has been performed and no assurance is given.
GRC-C09 / RISKILLUSTRATIVE
Demonstrate recovery in an authorised test
Risk addressed: A recovery plan relies on backups or dependencies that have not been shown to restore the required service or information.
- How it could operate
- In this example, the responsible technical owner conducts an authorised restoration test within agreed boundaries, checks the recovered outcome and records failed assumptions and follow-up work.
- Evidence to look for
- The approved test objective, environment, scope and safeguards.
- Restoration records showing what was recovered and what checks were performed.
- The outcome, limitations, unresolved dependencies and follow-up test plan.
Suggested test, trigger & failure indicator
Test: Select a claimed successful recovery test; compare the result with its stated objective and inspect the evidence of usable recovery. Identify elements supported only by discussion or assumption.
Suggested review trigger: a significant service or backup change, an unsuccessful test or the chosen recovery-testing programme.
Possible failure: A successful backup job is presented as restoration evidence, or recovered information has not been checked for usability.
Example only. No test has been performed and no assurance is given.
GRC-C10 / RISKILLUSTRATIVE
Review material service changes before rollout
Risk addressed: A product, hosting or access change introduces exposure that the accountable service owner has not considered.
- How it could operate
- In this example, the change owner records affected services and dependencies, gathers proportionate test evidence and obtains a decision on unresolved risks and rollout conditions.
- Evidence to look for
- The change description, affected service and risk assessment.
- Relevant test results and the assumptions or dependencies left untested.
- The approval, rollout conditions and subsequent check of the changed service.
Suggested test, trigger & failure indicator
Test: Select a material completed change; compare its approved scope with the implemented change and inspect how failed tests, exceptions and approval conditions were handled.
Suggested operating trigger: a material product, AI-use, hosting, supplier or access change before rollout.
Possible failure: The implemented change differs from the approved scope or an unresolved test finding has no accountable decision.
Example only. No test has been performed and no assurance is given.
GRC-C11 / RISKILLUSTRATIVE
Challenge risk-register changes with evidence
Risk addressed: A risk assessment becomes stale or its residual score falls without evidence that current controls improved.
- How it could operate
- In this example, the risk owner compares current exposure with the previous decision, checks control evidence and records the reasons for score changes, treatment choices and escalation.
- Evidence to look for
- The previous risk assessment, objective and rating assumptions.
- Current control evidence, incidents, near misses and relevant changes.
- The revised assessment, reasons, treatment decision and review trigger.
Suggested test, trigger & failure indicator
Test: Select risks with reduced residual ratings and risks affected by incidents; trace the change in assessment to current operating evidence and identify any planned controls counted prematurely.
Suggested review trigger: a changed dependency, missed control, incident, near miss or agreed risk-review point.
Possible failure: The residual score is reduced because a control is planned, or a material change leaves the old assessment untouched.
Example only. No test has been performed and no assurance is given.
GRC-C12 / RISKILLUSTRATIVE
Exercise the incident route with an unavailable contact
Risk addressed: An incident response stalls when the usual decision-maker, supplier contact or communication channel is unavailable.
- How it could operate
- In this example, a facilitator runs a clearly marked, bounded scenario with the actual responders, introduces an unavailable contact and records where authority or information cannot be located.
- Evidence to look for
- The scenario objective, participants, boundaries and stop conditions.
- A timeline of simulated developments, attempted decisions and information gaps.
- The debrief, assigned improvements and results of repeating failed steps.
Suggested test, trigger & failure indicator
Test: Review an exercise record and follow one observed failure through its action and repeat test. Distinguish demonstrated response capability from an intention to update the plan.
Suggested review trigger: changed response roles or suppliers, an incident lesson or the agreed exercise programme.
Possible failure: Responders cannot locate a fallback decision-maker, or a failed step recurs without evidence of follow-up.
Example only. No test has been performed and no assurance is given.
GRC-C13 / COMPLIANCEILLUSTRATIVE
Connect an obligation to an operational outcome
Risk addressed: A requirement is recorded without a reasoned scope decision, accountable owner or evidence of performance.
- How it could operate
- In this example, the obligation owner checks the source and applicability, identifies the process intended to fulfil it and records where evidence of performance can be inspected.
- Evidence to look for
- The precise source, provision or commitment and version checked.
- The affected entity and activity, applicability rationale and unresolved questions.
- The responsible owner, operating control and recent performance record.
Suggested test, trigger & failure indicator
Test: Select consequential register entries; trace each from the recorded source and scope decision to a recent process outcome. Record unclear interpretation and missing evidence separately.
Suggested operating trigger: a new activity or commitment, a source change or the chosen applicability review.
Possible failure: The entry contains only a broad legal title or policy link, with no identifiable outcome or delivery owner.
Example only. No test has been performed and no assurance is given.
GRC-C14 / COMPLIANCEILLUSTRATIVE
Verify implementation after a regulatory change
Risk addressed: A source update leads to amended documents while the affected systems, staff or processes remain unchanged.
- How it could operate
- In this example, the change owner records source status and applicability, maps affected operations, assigns implementation work and checks an actual process outcome before proposing closure.
- Evidence to look for
- The official source, status and relevant dates checked.
- The applicability assessment and map of affected policies, systems and people.
- Implementation records and a post-change check with unresolved issues visible.
Suggested test, trigger & failure indicator
Test: Select a change marked implemented; follow one affected process through the revised procedure and compare the operating evidence with the planned outcome. Check that source dates and internal targets remain distinct.
Suggested operating trigger: a relevant official-source update or new information affecting the applicability assessment; actual deadlines need separate checking.
Possible failure: The action closes when drafting ends, although the affected system or staff instruction has not changed.
Example only. No test has been performed and no assurance is given.
GRC-C15 / COMPLIANCEILLUSTRATIVE
Review a changed processing activity
Risk addressed: A change to personal-data processing proceeds on an outdated description or an untested assumption about safeguards.
- How it could operate
- In this example, the project owner maps the changed processing, records the relevant screening and assessment decisions, and obtains evidence that important safeguards have been implemented and checked.
- Evidence to look for
- The current processing description and relevant information-flow changes.
- The screening decision, reasons and references to restricted assessment records.
- Safeguard implementation evidence, test results and unresolved questions.
Suggested test, trigger & failure indicator
Test: Choose a materially changed activity; compare the actual flow with the recorded description and trace one important safeguard to implementation and testing. Keep the review within its stated scope.
Suggested review trigger: a material change in purpose, scale, information, technology or supplier before the changed activity proceeds.
Possible failure: The assessment describes the old information flow or lists a safeguard for which no implementation evidence can be found.
Example only. No test has been performed and no assurance is given.
GRC-C16 / COMPLIANCEILLUSTRATIVE
Check AML applicability when a service changes
Risk addressed: A new or changed service inherits an AML scope or supervisory assumption that does not reflect the actual activity.
- How it could operate
- In this example, the responsible practice or service owner records the activity, checks current applicable sources and supervisory context, and assigns unresolved scope questions before the service change is approved.
- Evidence to look for
- The service description and the activities included or excluded from review.
- The source and supervisory references supporting the scope assessment.
- The reasoned decision, outstanding advice questions and resulting procedure or risk-review actions.
Suggested test, trigger & failure indicator
Test: Select a new or materially changed service; compare its actual activities with the recorded scope rationale and inspect whether unresolved questions reached the appropriate decision-maker.
Suggested operating trigger: a materially different service, relevant technology change or source update affecting the recorded assessment.
Possible failure: The assessment relies only on the business label or imports another sector's guidance without checking relevance.
Example only. No test has been performed and no assurance is given.
GRC-C17 / COMPLIANCEILLUSTRATIVE
Check learning through a role-specific decision
Risk addressed: Training completion is mistaken for an ability to follow the relevant process in everyday work.
- How it could operate
- In this example, the learning owner connects a role to a real decision, teaches the internal route, checks understanding with a scenario and reviews subsequent work for recurring errors.
- Evidence to look for
- The role, learning objective and version of the material used.
- Completion and scenario-check records, with support needs and follow-up.
- A proportionate sample of subsequent work and the response to recurring mistakes.
Suggested test, trigger & failure indicator
Test: Choose a trained role and its intended process outcome; compare scenario results with sampled work and inspect follow-up where the same error persists. State the limits of the sample.
Suggested review trigger: induction, a material role or process change, recurring errors or the training cycle selected for the applicable requirements and risks.
Possible failure: Completion is high but staff cannot identify the escalation route or the same work-quality problem remains unaddressed.
Example only. No test has been performed and no assurance is given.
GRC-C18 / COMPLIANCEILLUSTRATIVE
Keep incident notification decisions separate and current
Risk addressed: Incomplete facts, mixed reporting routes or an assumed generic deadline delay a properly informed notification decision.
- How it could operate
- In this example, the incident lead records known facts and awareness times, escalates to the appropriate decision-makers and maintains separate assessments of applicable notification duties as facts develop.
- Evidence to look for
- The incident timeline, information sources and outstanding uncertainties.
- Recorded impact assessments, organisational roles and decision authority.
- Each notification decision, reasons, applicable deadline checks and subsequent updates.
Suggested test, trigger & failure indicator
Test: Review a completed incident or clearly marked exercise; trace evolving facts to reassessed notification decisions and inspect whether different reporting routes and their timing were kept distinct.
Suggested operating trigger: incident detection or material new facts; urgent applicable duties are checked separately rather than deferred to a scheduled review.
Possible failure: The log uses one unexplained deadline for every reporting route or new facts do not prompt a recorded reassessment.
Example only. No test has been performed and no assurance is given.
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