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Policy Governance · 16 min read

Policy on Policies: How to Write One for a Growing Company

Sid Varma

A policy on policies is the master policy that sets out how your company writes, formats, approves, publishes, reviews and retires every other policy. It names who owns each policy, who signs it off, how often it gets reviewed and how people confirm they’ve read it, so policy work runs the same way every time instead of depending on whoever happens to be writing.

Most of what you’ll find on this topic was written for universities and state agencies, with committees, senates and forty-page procedures. This guide is for a company of 30 to 500 people that has outgrown a folder of documents nobody quite owns, and it is part of our wider guide to policy governance for growing companies.

Key takeaways

  • A policy on policies is one short policy that governs all the others, covering roles, approval, format, numbering, review, acknowledgment, exceptions and retirement.
  • Sort every document into tiers, because the tier decides who approves it and how often it is reviewed.
  • At 30 people it fits on a page, and at 500 people it grows to a few pages with an appendix of owners, while the stages stay the same.
  • Write it, approve it and get it acknowledged like any other policy, then follow it yourself, because the first thing an auditor checks is whether you do.

What is a policy on policies?

A policy on policies, sometimes called a policy management policy, a policy framework policy or a policy development procedure, is the rulebook for your rulebook. It doesn’t tell anyone how to book leave or handle customer data, but it tells the people who write those policies how a policy gets created, what it has to look like, who must approve it before it counts, how it reaches employees and when it must be looked at again.

Without one, every policy is a small project with its own rules. One manager writes a two-page policy and emails it round, another writes twelve pages that nobody approves, and a third copies a template that contradicts both. A policy on policies replaces those habits with one agreed process, and it gives a new policy owner a clear answer to the question “what do I actually have to do?”

Why a growing company needs one

The problems a policy on policies solves show up gradually as a company grows, and they tend to surface all at once when someone outside the business asks for proof.

Policies contradict each other. The remote work policy says one thing about home equipment and the information security policy says another, because two people wrote them a year apart and nobody checked one against the other.

Policies are orphaned. The person who wrote the expenses policy left eighteen months ago, so nobody updates it, nobody answers questions about it, and nobody notices when it falls out of date.

Nobody can prove a policy was approved. The file exists, but there is no record of who agreed it was right or when it came into force, which is the first thing an auditor or a customer’s security review will ask.

Reviews never happen. Without a review date written into each policy, the only time anyone revisits a policy is after something goes wrong.

Outside rules expect this kind of control too. Having been through ISO 9001 audits more than ten times, I know document control is never optional, because the standard asks you to approve documents before use, review and update them, identify changes and the current version, and make sure the right version is available where it is used. SOC 2 asks that controls are deployed through policies that set out expectations, healthcare rules require written policies to be kept, reviewed periodically and made available to the people who use them, and federal compliance program guidance puts written policies and procedures first among the elements of an effective program, which we cover in our guide to building a compliance program.

Sources: ISO 9001:2015 clause 7.5, Control of documented information, AICPA Trust Services Criteria CC5.3, 45 CFR 164.316 (HIPAA Security Rule documentation), HHS-OIG General Compliance Program Guidance, November 2023

Three tiers of documents, three levels of approval. Governance policies, such as the code of conduct, the policy on policies itself, conflict of interest, information security and records retention, are approved by the CEO or leadership team and the board where one exists, and reviewed every 12 months. Company policies, such as leave, remote work, expenses, acceptable use, health and safety and anti-harassment, are approved by the department head, then a leadership sign-off for anything touching law or money, and reviewed every 12 to 24 months. Procedures and SOPs, such as how to request leave, how to set up a new laptop and how to run the monthly close, are approved by the policy owner or the team lead who runs the process, and reviewed when the process changes and at least every 24 months.
Tiers do most of the work: once a document has a tier, everyone knows who approves it and when it is due for review.

What a policy on policies should include

The twelve sections below make a complete policy on policies for a growing company. Use all twelve if you have more than about a hundred people, and merge them into five or six short paragraphs if you’re smaller, because the ideas matter more than the headings. The examples show how a company like ShiftTilt Inc, with about 120 people, might fill each one in.

SectionWhat it saysExample for ShiftTilt Inc (about 120 people)
1. PurposeWhy the company manages policies in one consistent way“So every policy is approved, current, easy to find and provably read by the people it applies to.”
2. ScopeWhich documents it covers and which it doesn’tAll company policies and procedures; customer contracts and marketing copy are out of scope.
3. DefinitionsWhat counts as a policy, a procedure, a standard and a guidelineA policy says what must happen and why; a procedure says how, step by step.
4. TiersThe levels of document and what belongs in eachGovernance policies, company policies, procedures (see the diagram above).
5. RolesWho requests, owns, drafts, approves and coordinatesEach policy has one owner role, such as Head of People; the Operations Manager coordinates the library.
6. Approval authorityWho signs off on each tier, and in what orderGovernance: owner, then CEO. Company: owner, then department head, then CEO where law or money is involved.
7. FormatThe standard header and the sections every policy must haveTitle, number, owner, approver, effective date, review date, who it applies to, related documents.
8. Numbering and namingHow policies are numbered, named and versionedArea prefix plus number, such as HR-004 or SEC-002, with version numbers that only go up.
9. Communication and acknowledgmentHow approved policies reach people and how reading is recordedEvery new or changed policy goes to the people it applies to for acknowledgment, with automatic reminders.
10. ReviewHow often each tier is reviewed and what a review producesGovernance every 12 months, company policies every 12 to 24 months, procedures when the process changes.
11. ExceptionsHow someone asks to depart from a policy, who decides, and how it is recordedA written request to the policy owner, approved by the owner’s manager, time-limited and logged.
12. Retirement and recordsHow a policy is withdrawn and how old versions are keptRetired policies are removed from view but every version and its approval record are kept.

Two sections cause most of the arguments, so settle them early. The first is the definitions, because the line between a policy and a procedure decides who can change what: if procedures can be updated by the policy owner while policies need leadership sign-off, people need to know which is which. The second is approval authority, because a policy on policies that says “approved by management” without naming a role will be read differently by every manager who uses it.

Who approves policies at a growing company

Name roles rather than people, so the policy survives someone leaving. At 50 to 500 people the cast is usually small, and the same person may hold two of these roles, which is fine as long as nobody approves a policy they wrote on their own.

WhoTheir job in the policy processTypical person at 50 to 500 people
RequesterRaises the need for a new or changed policyAnyone, though usually a manager, an auditor’s finding or a customer request
Policy ownerAccountable for the policy’s content, keeps it current, answers questions about itA role such as Head of People, IT Manager or Quality Manager
ApproverConfirms the policy is right and can be put in forceDepartment head, CEO, an outside lawyer for anything with legal weight
Policy coordinatorKeeps the library tidy, chases review dates, runs this policyAn operations, HR or compliance lead, often part-time
Board or leadership teamApproves the governance tier and the policy on policies itselfThe leadership team, or the board where the company has one

Our guide to the policy owner role goes deeper on the role people most often leave blank, and the one that matters most once the policy is in force.

Order matters as much as names. A sensible path for a company policy is owner first, then the department head, then the CEO only when the policy carries legal or financial weight, so the CEO isn’t reading every procedure while the important policies still get senior eyes. An outside lawyer can sit in the path too, as an approver on the policies where their sign-off matters.

Animation of an AllyMatter approval workflow. First, the workflow Policy Review: Draft, then a 1st approval by Epictetus Freed, then a 2nd approval by Lao Tzu Chen, each set to Any approver, then Done. Then the approval record for the Remote Work Policy, sent by Paul Carus, with Step 1 completed and approved by Epictetus Freed and Step 2 completed and approved by Lao Tzu Chen, each step outlined in turn.
An approval path written into the policy on policies becomes a workflow every policy in the folder follows, and the record shows who approved each step, captured from the live app.

The policy lifecycle, from request to retirement

The heart of a policy on policies is the lifecycle every policy follows. Seven stages cover almost every company, and writing them down means a manager with a new policy to write can start at stage one without asking anyone how it works.

The life of one policy, as a policy on policies defines it, in seven stages. 1 Request: someone names the need, such as a new law, an audit finding, a customer ask or a gap. 2 Draft: the policy owner writes it in the standard format, with a number and a tier. 3 Consult: the people affected, plus legal or HR where needed, comment on the draft. 4 Approve: the approvers for its tier sign off in order, and a rejection comes with a reason. 5 Publish: only the approved version goes out, to the people it applies to. 6 Acknowledge: each person confirms they read it, and the record keeps their name and the version. 7 Review or retire: on its review date the owner confirms it, revises it or retires it. Any change starts again at stage 4: a revised policy goes back through approval and out for acknowledgment, however small the edit.
Seven stages, and one rule that holds them together: any change goes back through approval and out for acknowledgment again.

The rule at the bottom of that diagram is the one most policies on policies leave out. Many allow “minor” edits to skip approval or re-acknowledgment, and the trouble is that nobody agrees what minor means, because a single changed word in a disciplinary or safety clause can change what people have to do. We built AllyMatter so that every new version goes back through approval and out for acknowledgment, with no exception for small edits, and our post on re-acknowledging policy updates explains how to make that painless for staff.

Acknowledgment deserves its own sentence in the policy on policies. Say who must acknowledge each tier, how soon after publication, and what happens if someone doesn’t, and decide whether some policies need a formal yearly confirmation as well, which our guide to policy attestation covers.

Review cycles that people actually keep

A review date is only useful if someone sees it coming. Put the cycle for each tier in the policy on policies, put the next review date on every policy, and define what a review produces: either a confirmation that the policy is still right, which is recorded, or a revised version that goes back through approval.

DocumentSensible review cycleAlso review when
Policy on policiesEvery 12 monthsThe company changes shape, such as a new department or a merger
Code of conduct, conflict of interest, information securityEvery 12 monthsA law, a certification or a major customer requirement changes
HR and workplace policiesEvery 12 to 24 monthsYou cross a headcount threshold or open in a new location
Safety programsEvery 12 monthsAn incident, a new hazard or new equipment
Procedures and SOPsWhen the process changes, at least every 24 monthsA mistake shows the written steps no longer match the work

Stagger the dates. If every policy is due in January, the review becomes a month of rubber-stamping, whereas spreading reviews across the year gives each owner one or two policies at a time and a real chance to read them.

AllyMatter Document Settings for a policy, showing visibility set to Public, the approval workflow Policy Review, the tag Global inherited from the parent folder, and under Document lifecycle a Review by date of Oct 22, 2027 with a note that a review alert will appear on the document until it is re-approved, and Recurring Review switched on for every 12 months.
Each policy carries its own approval workflow and review cycle, so the rules in your policy on policies are set once on the policy rather than tracked somewhere else.

Format, numbering and naming conventions

A standard format makes policies faster to write, easier to read and much easier to audit, because everyone knows where to find the owner, the effective date and the review date. Ask every policy to open with the same header block:

  • Title and number, such as HR-004 Remote Work Policy
  • Owner, as a role rather than a name
  • Approved by, the role or roles that signed it off
  • Effective date and next review date
  • Applies to, the teams, locations or roles in scope
  • Related documents, such as the procedures and forms that carry it out

Then ask for the same body sections in the same order: purpose, scope, the policy itself, responsibilities, and what happens if it isn’t followed. A short prefix per area keeps numbering simple, such as HR, SEC for information security, FIN, OPS, QA and HS for health and safety, and numbers that are never reused stop an old reference from pointing at a new policy.

Version numbers should only ever go up. A version that is restored or re-issued still gets a new number, so an auditor can line up exactly which text was in force on any date and who had acknowledged it, and a word-by-word comparison between versions shows precisely what changed.

Exceptions and retirement

Every policy meets a situation it didn’t foresee, so decide in advance how exceptions work rather than letting managers improvise. A good exceptions section says who can ask, who decides, how long an exception lasts and where it is recorded, and it treats a pile of exceptions to the same policy as a sign that the policy needs rewriting.

Retirement needs the same care. When a policy is withdrawn or replaced, it should disappear from everyday view so nobody follows it by mistake, while its versions and approval history are kept for as long as your records rules require. Our guide to the records retention schedule covers how long to keep them, and governance policies like a conflict of interest policy usually sit in the top tier alongside the policy on policies itself.

How a policy on policies grows from 30 to 500 people

You don’t need the university version on day one. A 30-person company can cover everything in a page, and the document grows only as new roles and approvers appear, while the lifecycle stays the same at every size.

How a policy on policies grows with the company. At about 30 people: one or two pages, two tiers (policies and procedures), the founder or CEO approves everything, two or three people own all policies, one yearly pass over everything, and an acknowledgment record per person as proof. At about 100 people: three to five pages, three tiers (governance, company, procedures), department heads approve with the CEO for governance policies, one named owner role per policy, staggered review dates by tier, and acknowledgment plus an approval record. At about 500 people: five to eight pages plus an appendix of owners, three tiers with department sub-libraries, owners, department heads, a policy committee and the board approve, an owner role per policy plus a policy coordinator, review dates by tier reported to leadership, and a full audit trail an auditor or customer can export.
The stages stay the same as you grow, while the number of approvers, owners and tiers rises with headcount.

How to write your policy on policies in a week

Day one: list what you have. Gather every policy and procedure in one place, note who wrote each one and when it was last changed, and mark the ones nobody owns.

Day two: choose tiers and owners. Sort each document into a tier and give each one an owner role, and expect a few uncomfortable conversations about policies nobody wants.

Day three: set approval paths and review cycles. Agree who approves each tier and in what order, and give every policy a review date spread across the coming year.

Day four: write it. Use the twelve sections above, keep it short, and write in the same plain language you want every other policy to use.

Day five: approve it, publish it and follow it. Put the policy on policies through its own top-tier approval, send it to everyone who writes or approves policies for acknowledgment, and then bring your most important policies into line with it first.

The last step is the one that counts. A policy on policies that the company ignores is worse than none, because it shows an auditor a process you said you would follow and didn’t, so start with the handful of policies that matter most and work through the rest at each review.

How AllyMatter runs your policy on policies for you

We built AllyMatter so that the process written in your policy on policies is the process the software follows, rather than a document people are supposed to remember.

Tiers become folders with their own approval paths. An approval workflow attached to a folder applies to every policy saved there, so governance policies always go to the CEO and procedures stay with their owners.

Every policy has a named Editor. The person responsible for keeping each policy current is its Editor, so there is never a document without someone accountable for it.

Only approved versions reach people. A policy is locked while it is being reviewed, a rejection needs a written reason, and drafts never reach staff.

The right people get each policy. Tags for teams, locations and roles decide who sees each policy and who is asked to acknowledge it, and the request can be a simple notification or an acknowledgment with automatic reminders.

Reviews and retirement are built in. Each policy carries a fixed or repeating review date, and an expiry date takes a retired policy out of everyone’s view while its history stays on record.

The record writes itself. Every step lands in the policy’s audit trail, so when an auditor asks how you control your policies, you show them the policy on policies and then the trail that proves you followed it.

Animation scrolling through the AllyMatter audit trail of a Remote Work Policy, newest first: approvals, re-approval requests, saved versions, a visibility change, acknowledgments, acknowledgement requests, a rejection with its comment, the workflow being added and started, the review by date, and the document being created.
One policy’s real audit trail, showing each stage of the lifecycle your policy on policies describes, from creation to the latest approval.

For the full picture of how the pieces fit together, from ownership to attestation to records, start with our policy governance guide or our guide to policy management software for small and growing businesses.

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Questions about a policy on policies

What is a policy on policies?

A policy on policies is the master policy that sets out how a company creates, formats, approves, publishes, reviews and retires all of its other policies. It names who owns each policy, who approves it, how often it is reviewed and how employees confirm they have read it.

Is a policy on policies the same as a policy framework?

They overlap. A policy framework usually describes the whole structure of policies, standards and procedures, while the policy on policies is the single written policy that puts that framework into force and makes it binding on everyone who writes or approves a policy.

Does a small company need a policy on policies?

Once more than one or two people write policies, yes, even if it is only a page long. It is the cheapest way to stop contradicting policies, missed reviews and policies nobody can prove were approved, and auditors and enterprise customers often ask how you control your documents.

Who should approve the policy on policies?

The CEO or the leadership team, and the board where the company has one. Because it governs every other policy, it should sit in the top tier and be reviewed at least once a year.

How often should company policies be reviewed?

Most companies review governance policies every 12 months, other company policies every 12 to 24 months, and procedures whenever the process changes. Many standards and regulators expect a periodic review, and a change in law, an audit finding or an incident should trigger one early.

What is the difference between a policy and a procedure?

A policy states what must happen and why, and changes rarely. A procedure explains how to do it, step by step, and changes whenever the process changes. A policy on policies usually lets a policy owner approve procedure changes, while policy changes need a higher sign-off.

Where should a policy on policies be kept?

In the same place as the policies it governs, approved, versioned and acknowledged like any other policy, so the people who write and approve policies can always find the current rules.

A policy on policies is the shortest important document most growing companies never write, and it is the one that makes every other policy easier to write, approve, find and prove.

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