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I don’t think it’s malicious. I usually see it happen when the company staff in charge of working with the auditors either aren’t interested in engaging (often due to stigma and baggage about the compliance industry) or don’t realize the dynamic of what they’re responsible for.

The auditors want you to get the Type 1. To do that they need docs and policies. If they say “send us your change management policy” and your team either says “we don’t have one, what would it look like” or sends them a one-line policy that says “The team does change reviews”, the auditors are going to send back recommendations for what you should include. They’re trying to be helpful (within the specific scope of getting you a type 1), but they aren’t engineers and don’t know your system. So a lot of their advice is going to be irrational and scope-creep. As a mundane example: the easiest thing for them to suggest if your change management policy doesn’t exist or looks weak to them is “set up a change control board that meets weekly to review all changes”, but that would be nuts to implement.






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