How Often Should You Review Compliance Policies?

Policies and procedures are the backbone of every compliance program, defining expectations, guiding employee behavior, and demonstrating accountability to regulators and auditors. Most organizations spend time developing initial policies, but having them in place isn’t enough.

As technology, threats, and regulations evolve, policies can quickly become outdated. Regular reviews are essential to ensure your documentation aligns with current laws and accurately reflects your organization’s practices.

From financial aid offices covered under the Gramm-Leach-Bliley Act (GLBA) to healthcare providers governed by HIPAA, maintaining up-to-date policies is both a regulatory requirement and a best practice in risk management.

The question is: how often should you review them?

Key Takeaways

Before diving into specific regulations, it’s important to understand the overarching principles that guide policy review frequency and scope. These key points set the stage for building a consistent, compliance-ready approach.

• Regulatory frameworks expect regular review and updates; many specify annual or bi-annual cycles.
• Policy reviews should be risk-driven, focusing on high-impact areas first.
• Version control, stakeholder involvement, and documentation are essential for demonstrating compliance.
• Technology and regulatory changes often trigger out-of-cycle reviews.

Recommended Review Cycles by Regulation

Different regulations impose varying expectations on how often policies and procedures should be reviewed. Understanding these nuances helps ensure your organization stays compliant and audit-ready while managing review workloads efficiently.

• PCI DSS (Payment Card Industry Data Security Standard)
  • Who it applies to: Organizations handling cardholder data.
  • Expectation: PCI DSS v4.0 explicitly requires annual reviews of all security policies, procedures, and system configurations.
  • Why it matters: Regular reviews help maintain compliance and protect against emerging payment-related threats.
• GLBA (Gramm-Leach-Bliley Act)
  • Who it applies to: Financial institutions, including higher education institutions managing student financial data.
  • Expectation: Policies and procedures must be reviewed at least annually as part of the institution’s information security program.
  • Why it matters: Annual reviews ensure safeguards reflect evolving risks, vendor relationships, and technology changes.

• FERPA (Family Educational Rights and Privacy Act)
  • Who it applies to: Educational institutions receiving federal funding.
  • Expectation: FERPA doesn’t mandate a review frequency, but best practice recommends annual or bi-annual reviews, especially as systems or data-sharing practices change.
  • Why it matters: Keeping student data privacy policies current reduces legal and reputational risk.

• HIPAA (Health Insurance Portability and Accountability Act)
  • Who it applies to: Healthcare organizations and business associates.
  • Expectation: The Security Rule requires organizations to periodically review and update policies and procedures in response to environmental or operational changes.
  • Best practice: Review policies annually or whenever there’s a change in processes, systems, or threats.

Best Practices for Policy and Procedure Reviews

Knowing how often to review policies is only part of the equation. The “how” matters just as much. The following best practices will help you establish a structured, efficient, and defensible policy review process that keeps your organization compliant and proactive.

1. Adopt a Formal Review Schedule
   Establish a documented review calendar, assigning ownership and due dates for each policy category.
2. Use a Risk-Based Approach
   Prioritize reviews for high-risk areas like data protection, incident response, and access control. Low-impact policies can follow a longer review cycle.
3. Engage Cross-Functional Stakeholders
   Include compliance officers, IT, HR, and department leads to ensure policies reflect operational realities. Clearly define due dates for collecting feedback from stakeholders, and schedule working sessions with the teams to review comments and questions.
4. Maintain Version Control and Audit Trails
   Track all edits, approval dates, and reviewers. This documentation is critical during audits.
5. Integrate Reviews into Change Management
   Don’t wait for the annual review. Trigger updates when new technologies, vendors, or regulations arise.
6. Test Policy Effectiveness
   Conduct tabletop exercises or mock audits to ensure policies are not only written well but implemented correctly.

Actionable Steps for Compliance Teams

These steps provide a structured way to operationalize best practices and maintain continuous compliance.

1. Inventory All Current Policies and Procedures.
   Identify which are compliance-related (GLBA, HIPAA, FERPA, PCI DSS, etc.) and which are operational.
2. Assign Policy Owners.
   Designate a responsible party or department for each policy to ensure accountability.
3. Establish a Policy Review Matrix.
   Create a living document that lists each policy, its review frequency, last review date, and next scheduled review.
4. Conduct Annual Cross-Regulation Review Meetings.
   Coordinate reviews across teams to ensure alignment between overlapping compliance requirements.
5. Document Everything.
   Keep records of review discussions, approval emails, and version history to show auditors evidence of due diligence.
6. Automate Where Possible.
   Use CampusGuard’s GRC and document management tools to set reminders, route approvals, and maintain version control automatically.

Final Thoughts

Policy and procedure reviews are more than an administrative task. They’re a cornerstone of compliance and organizational integrity. Regulators want to see that you’re not just creating policies but actively maintaining and applying them.

Whether you’re governed by GLBA, FERPA, HIPAA, or PCI DSS, an annual review cycle supported by risk-based updates is the gold standard. By building review activities into your compliance culture and leveraging technology to stay organized, your institution can stay audit-ready, resilient, and confident that its policies reflect today’s risks.

CampusGuard can help you take your policy review process to the next level. Our teams can help align policies with security frameworks like the NIST SP 800-171, and ensure policies, standards, and guidelines are clearly communicated and accessible to staff.

Contact us to learn more about a policy and procedure review engagement. Get started today!