Publish information on your entity’s decision-making processes, decisions made, successful tenderers or grantees, incidents and breaches.
Why this countermeasure matters
Transparency in decision making:
- deters fraud
- makes fraud harder to conceal.
Being transparent when fraud occurs disrupts fraud by making fraudsters aware that their activity has been detected and is being investigated.
How you might apply this countermeasure
Some ways to implement this countermeasure include:
- publishing information on:
- your entity’s decision-making processes
- entities or individuals receiving government funding
- which decisions have been made
- approved providers or licence holders
- conflicts of interest on external influences
- fraud incidents
- notifying the Office of the Australian Information Commissioner of data breaches.
How to check if your countermeasures are effective
Here are some ways to measure the effectiveness of this type of countermeasure:
- review decision making procedures
- review information published on decisions
- interview staff and stakeholders to identify their awareness of decisions
- confirm the existence of reference and guidance material
- review conflict of interest registers
- review how fraud incidents are reported and communicated.
Establish governance, accountability and oversight of processes by using delegations and requiring committees and project boards to oversee critical decisions and risk. Good governance, accountability and oversight increases transparency and reduces the opportunity for fraud.
Clearly document decision-makers using delegations, authorisations and instructions. Clearly defined decision-making powers increase transparency and reduce the opportunity for fraud and corruption.
Provide staff with adequate training to increase likelihood that correct and consistent processes and decisions will be applied.
Use system workflows to make sure all requests, claims or activities are approved only by the appropriate decision-maker.
Prepare summary reports on activities for clients, managers or responsible staff.