A risk register shows an action as overdue, but its owner says it was completed last month. The evidence is in an email. A spreadsheet contains the latest update, while the governance report still reflects the previous position. For the practitioner preparing that report, the immediate task is to establish what is accurate. The broader task is to understand why the organisation needs several rounds of checking before it can trust its own information.
Moving beyond a legacy governance, risk and compliance (GRC) platform starts with understanding this working environment. The software is only part of it. Forms, approval rules, reporting expectations, data definitions and informal workarounds all influence how risk information becomes a decision or an action.
Replacing the platform without examining those arrangements can move the same problems into a different interface. These ten steps help practitioners understand what they are working with, identify what needs to change and translate that understanding into practical requirements.
Start with a recent risk assessment, compliance review, incident or audit finding. Follow what happened from the initial entry through to action, evidence, review and reporting. Do not rely only on the documented procedure. Ask the people doing the work to demonstrate how they complete it, including the spreadsheets, emails and shared folders they use along the way.
Record:
- Where information is first captured and where it is entered again.
- Who checks, approves or changes it.
- Where the work waits for another person.
- How completion is confirmed and evidence is retained.
- How the information reaches management or a governance committee.
An action marked as complete, for example, may still require someone to locate supporting evidence and obtain a manager’s acceptance before it can be reported as closed. Those are distinct activities that the future workflow needs to recognise.
Practical output: A simple process map showing the actual work, handovers and supporting tools, not just the intended procedure.
Similar symptoms can have different causes. Repeated email reminders may indicate that the platform cannot send useful notifications. They may also indicate that ownership is unclear, deadlines are unrealistic or overdue actions have no agreed escalation route. For each problem, distinguish between:
Technology:The platform cannot support a necessary activity, connection or access requirement.
Process: The workflow contains unnecessary steps, unclear rules or avoidable duplication.
Information: Records are incomplete, inconsistent, outdated or difficult to interpret.
Accountability: People do not understand their responsibilities or lack authority to act.
More than one cause may apply. A notification can remind an owner that work is overdue, but it cannot decide who should own the work or whether a deadline extension is justified.
Use specific problem statements. “Reporting is difficult” provides little direction. “The risk team checks action status with each business unit because completion evidence is not consistently recorded” identifies something that can be investigated and addressed.
Practical output: A prioritised issue log recording the symptom, likely causes, operational consequence and person responsible for resolving it.
Before moving records, establish where the authoritative version of each type of information sits. An authoritative source is the agreed place from which information is maintained and relied on; it is not necessarily the application holding the most copies.
For risks, controls, obligations, incidents and actions, record:
- Where the current record is maintained.
- Who owns its accuracy and review.
- Which other records or documents it depends on.
- Whether another team maintains a competing version.
- How changes are communicated or transferred.
Check definitions as well as locations. One team may use “closed” to mean that work has been completed, while another uses it only after independent verification. Combining those records without resolving the difference would produce misleading reporting.
A shared source of risk information does not require every document or employee record to move into the GRC platform. Some information should remain in another authoritative application, with an appropriate link or integration.
Practical output: An information inventory with agreed sources, owners, definitions and known quality issues.
A name against a record is not enough to establish accountability. Define the decisions and activities attached to each role. For corrective actions, for example, distinguish between:
- The person responsible for completing the work.
- The manager authorised to approve a revised deadline.
- The person who reviews completion evidence.
- The person authorised to accept closure or escalate an unresolved issue.
Apply the same discipline to risk ownership, control operation, compliance reviews and information maintenance. Roles may be combined where appropriate, but the arrangement should be deliberate and consistent with required oversight. Include what happens when someone changes role, leaves the organisation or is unavailable.
A workflow that depends on a single individual needs a reassignment or delegation route. Practitioners should also identify which decisions require executive sponsorship. Cross-functional ownership disputes should not be left for an implementation team to resolve through configuration.
Practical output: An agreed responsibility model covering routine work, approvals, exceptions, escalation and ongoing administration.
Turn the problems identified so far into outcomes that can be observed and tested. Instead of “improve visibility”, specify that an authorised manager should be able to view overdue actions for their business area, identify the accountable owner and see the latest update without requesting a separate spreadsheet. Instead of “improve assurance”, specify that a reviewer should be able to trace a control assessment to its supporting evidence, assessment date and unresolved findings.
For each outcome, establish:
- The current position or baseline.
- The proposed change in how work is completed.
- The evidence that would demonstrate improvement.
- The person who will confirm the outcome has been achieved.
Measures might include report preparation time, records returned for correction or actions closed without the required evidence. Use the organisation’s starting point rather than assumed savings.
Practical output: A short set of measurable outcomes and acceptance criteria to guide design, evaluation and post-implementation review.
Review existing forms, assessment templates, mandatory fields and approval steps before reproducing them. For each field, identify who uses the information and what decision, obligation or reporting requirement it supports. For each approval, identify what the approver is expected to verify and what authority they exercise.
A mandatory field that produces placeholder text may indicate that the question is unclear, asked too early or irrelevant to some records. Removing it is not automatically the answer. The requirement may need better wording, conditional display or collection at a later stage.
Similarly, an approval that adds no meaningful review may be unnecessary, while a closure check that confirms the adequacy of evidence may remain essential.
Test proposed changes with operational users and control owners. Preserve legitimate differences between business areas where they reflect different obligations or working conditions. Standardisation should create consistency where it is useful, not erase necessary distinctions.
Practical output: Agreed future workflows with a documented reason for retained requirements, changes and exceptions.
Translate the future workflows into scenarios that a provider or implementation team can demonstrate from beginning to end. A corrective action scenario might include:
1. Record a finding and link it to the relevant risk or control.
2. Assign an action, accountable owner and due date.
3. Submit a progress update and request a deadline change.
4. Escalate an overdue action to the appropriate manager.
5. Submit completion evidence for review. 6. Reject insufficient evidence or approve closure.
7. Produce a report showing the current position and relevant history.
Include exceptions, not just the straightforward path. Test an owner leaving, an action being reopened, a sensitive attachment requiring restricted access and a business unit changing its structure.
Ask operational users to assess usability, while IT and information security review access, authentication, integration and security requirements. Check which activities are supported through configuration, which require development and which depend on an external process. If a replacement is already selected, these scenarios can still validate the proposed design before it is finalised.
Practical output: A scenario-based assessment recording demonstrated capability, gaps, dependencies and acceptance decisions.
Migration should be selective and accountable. Classify data and processes into four categories:
Confirm applicable retention requirements, legal holds, privacy obligations and audit needs with the relevant specialists before disposal. Retiring a process does not necessarily permit deletion of its history.
Preserve the relationships needed to interpret records. An action without its originating finding, or a control assessment without its evidence, may be less useful even if the record itself transfers successfully.
Choose a first rollout phase that delivers a complete operational benefit. Action management in one business area, for example, should include assignment, follow-up, evidence review and reporting rather than moving only the action list.
Practical output: A migration decision log recording the decision, rationale and accountable owner.
A matching record count does not establish that a migration has succeeded. Practitioners need to confirm that people can find, interpret and use the information correctly.
Ask business owners and representative users to test complete workflows and reports. Record defects and agree which issues must be resolved before go-live.
Prepare role-specific guidance, a support route and clear cutover communications. Define when the old system stops accepting updates, where authoritative records will sit and how exceptions will be handled. Agree contingency arrangements and go-live approval responsibilities.
Practical output: A tested cutover plan with business sign-off, user support and contingency arrangements.
After go-live, revisit the original problems and outcomes. Login activity can show that people accessed the platform, but it does not establish that information is accurate or that the intended work is being completed.
Review whether people can complete the work correctly and whether information is being maintained. Login activity alone will not establish this. Compare operational measures with the baselines set earlier and investigate continuing spreadsheet or email workarounds.
Use the findings to refine workflows before expanding the rollout. Once retention, access and transition requirements are satisfied, formally decommission the legacy environment and end unnecessary duplicate processes.
Practical output: A post-implementation review, an improvement backlog and an approved legacy-system closure plan.
Moving beyond legacy GRC is an opportunity to reconsider how information is captured, responsibilities are assigned and evidence supports decisions.
The strongest starting point is not a commitment to migrate everything. It is agreement on what needs to work better, followed by deliberate choices about what to preserve, redesign and leave behind.
A new platform should support that work, making it easier for people to maintain reliable information, act on their responsibilities and give decision-makers a clear view of risk. It should not inherit every constraint of the old environment simply because those constraints have become familiar.
That means preserving the controls, evidence and organisational knowledge that remain valuable, while challenging duplicate data entry, unnecessary approvals and workarounds that no longer serve a purpose. The measure of success is not how closely the new system resembles the old one. It is whether people can carry out essential governance, risk and compliance work with less friction, clearer accountability and information they can trust.