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Heidemarie Paulitsch
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Michail Fouzailov
Since ISO 19600 follows the ISO "High Level Structure" ("HLS"), it can be
implemented in already existing management systems that are using the HLS
standard. Since ISO 19600 follows this HLS, it can serve as an additional module for
those companies having already implemented ISO's quality management standards
according to ISO 9000 et seq. This approach makes it easier and therefore more
likely for companies to implement the CMS measures recommended in ISO 19600.
The ISO 19600 guideline also follows a risk-based approach. After establishing the
context in which it operates, the organization must perform a compliance risk
assessment. The identified risks (compliance obligations) are the basis for
establishing and implementing controls. The performance of those risk treatment
measures must then be evaluated and improved upon, as well as communicated
both internally and externally.
The structure of ISO 19600 focuses on the different stages of CMS integration from
development to implementation, evaluation, maintenance, and continual
improvement. After determining the objectives and the scope of the CMS, the
guideline recommends the appropriate measures in accordance with stakeholder
interests and good governance.
The guideline emphasizes the different roles, responsibilities, and authorities within
the organization and focuses on the establishment of a compliance policy. By doing
so, it aims to create an organizational culture in which compliance becomes the
general rule a compliance culture, so to speak.
The ISO standard also recommends measures for establishing controls and
procedures to achieve the desired behavior. The recommended measures should be
accompanied by trainings, internal and external communication, documented
information, and the top management's encouraging behavior. Finally, ISO 19600
THE INFORMATION IN THIS DOCUMENT IS INCLUDED WITH THE UNDERSTANDING AND AGREEMENT THAT SCHOENHERR IS NOT ENGAGED IN RENDERING LEGAL OR
OTHER PROFESSIONAL SERVICES BY POSTING SAID MATERIAL. THE INFORMATION AND OPINIONS CONTAINED IN THIS DOCUMENT ARE FOR GENERAL
INFORMATION PURPOSES ONLY, ARE NOT INTENDED TO CONSTITUTE LEGAL OR OTHER PROFESSIONAL ADVICE, AND SHOULD NOT BE RELIED ON OR TREATED AS A
SUBSTITUTE FOR SPECIFIC ADVICE RELEVANT TO PARTICULAR CIRCUMSTANCES. SCHOENHERR DOES NOT ACCEPT ANY RESPONSIBILITY FOR ANY LOSS WHICH MAY
ARISE FROM RELIANCE ON INFORMATION OR OPINIONS PUBLISHED IN THIS DOCUMENT.
THE INFORMATION IN THIS DOCUMENT IS INCLUDED WITH THE UNDERSTANDING AND AGREEMENT THAT SCHOENHERR IS NOT ENGAGED IN RENDERING LEGAL OR
OTHER PROFESSIONAL SERVICES BY POSTING SAID MATERIAL. THE INFORMATION AND OPINIONS CONTAINED IN THIS DOCUMENT ARE FOR GENERAL
INFORMATION PURPOSES ONLY, ARE NOT INTENDED TO CONSTITUTE LEGAL OR OTHER PROFESSIONAL ADVICE, AND SHOULD NOT BE RELIED ON OR TREATED AS A
SUBSTITUTE FOR SPECIFIC ADVICE RELEVANT TO PARTICULAR CIRCUMSTANCES. SCHOENHERR DOES NOT ACCEPT ANY RESPONSIBILITY FOR ANY LOSS WHICH MAY
ARISE FROM RELIANCE ON INFORMATION OR OPINIONS PUBLISHED IN THIS DOCUMENT.