Independent UK governance, risk & complianceOur editorial standards ↗Practical guidance. Accountable decisions.

The control starter library

Start with a control you can explain.

Eighteen illustrative controls with operating prompts, evidence examples, suggested sample tests and failure indicators. Adapt them to the actual risk, requirements and work.

18 illustrative startersEditable working copiesNot prescribed regulatory tests

Download an example working copy, open the control template and use Import JSON to begin. Replace the illustration with your own scope, evidence and findings. A starter is not proof that a control exists or works.

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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.