By Neil Quarmby, CEO Intelligence Rising
I have recently written a few blogs following Malcolm Sparrow’s three models of regulatory preference: function, process, and problem-solving. My intent was to draw insights for intelligence management in regulation. A synthesis of these thoughts/blogs follows. Please feel free to share your experiences!
Intelligence in a functionally oriented regulator
Intelligence teams in a functionally oriented organisation are rare and often narrowly confined – e.g., provide data extract support. However, with some effort, they can provide the missing ‘link’ between otherwise isolated functions. Understanding the disparate (and often divergent) tactical, operational and strategic decision-needs of a functionally-based organisation is important. Quietly harnessing information that spans the functions (often the ‘unknown’ for a regulator) and nudging it into assessments is crucial. The danger is being isolated as a separate function, disconnected from business because of the latest organisational re-design process. If still connected, there is a danger of getting bogged down in assessments peculiar to a function and not holding back some effort to develop new sources of information and new lines of inquiry that will assist the functional areas design new approaches to emerging problems.
Intelligence in a process oriented regulator
Cumbersome bureaucracy and process is often a point of intense frustration for analysts and hence many struggle in regulation. Fundamentally, the 'science' of process may undermine the creativity of the intelligence 'art'. However, it is important to invest time in process and procedures to underpin intelligence work. Intelligence managers' may need to consider how to:
Balance their own predisposition to process and structures.Trigger intervention by assessed harm and threat; and not by a pre-determining or artificial process.Ensure 'process noncompliance' (which is often actually 'process non-conformance’) is understood in the context of harm and threat i.e., the difference between functional and administrative non-conformance is clear.Initiate an assessment – this should not be cumbersome and require extensive permissions. Get decision-makers to focus on responding to the implications of an assessment and not on process, words used in the assessment, or knowledge gaps. Ensure products are not staffed through various ‘for-note’ committees and are represented to decision-makers by the analyst and their manager. Ensure corporate risk analysis procedures do not restrict the analyst's flexibility to use more pertinent analytical tools.Avoid unnecessary hurdles in collecting intelligence - beyond what is 'held' by the agency.
Intelligence in a problem-solving regulator
Malcolm Sparrow argues for problem solving cultures in regulators in The Character of Harms. The implications of working within a problem-solving culture for intelligence managers are profound. In such an organisation, intelligence is respected, necessary and drives action. While processes and structures are important, intelligence staff need to be trained and positioned to be flexibly appointed to problem identification, treatment support and treatment evaluation. Structures, process, training and systems need to recognise the differences between strategic, operational and tactical analysts as well as the decision-needs at those levels; yet also cater for sharing, movement and informed insights across levels. Embedding a system so it survives any organisational change back to “core” functional or process-driven models is also worth the investment.