Library Policy Management 103: Avoiding Policy Hijack

In my two previous posts, I discussed a couple of important principles of policy management: first, the fact that library policies are like carbohydrates – in that they're essential, but not all of them are equally healthy and it's easy to overindulge if you're not careful. Second, I described some healthy approaches to making, curating, and amending library policies.

In my third and final installment in this series, I want to touch on one very specific challenge that every library organization faces: the danger of what I call "policy hijack."

Policy hijack is what happens within an organization when rules emerge (and acquire informal authority) that are not actually based in formal policy. Sometimes these are relatively innocuous – every organization has a culture that arises to some degree organically, and rules are part of every human culture. A department may establish a process for collectively buying coffee, with rules about how much each person should contribute and around who should consume how much. Another department might have informal rules about how its meetings are conducted, and those rules may be very different from those of another department. This kind of informal, localized rule-making doesn't constitute what I'm calling "policy hijack." Policy hijack is usually library-wide, and manifests in two primary ways:

• The emergence of unauthorized, library-wide "policies," either organically or as the result of deliberate effort by groups or individuals
• The institution of policy by the imposition of procedural requirements

In the first case, these "policies" are usually implicit rules that arise as traditions but may be colloquially referred to as "policies" – which can create great confusion and distress in the organization. I addressed this issue more directly in last week's post, so I won't belabor it here. Today I want to focus more on the second problem: policy by procedure. Here's how it typically happens:

First, a formal policy is created. Let's say in this case it's a policy about the use of the library's van. The library administration, exercising its oversight responsibility for library-wide policies, approves the criteria that the facilities manager will apply when evaluating requests for the van. A policy document explaining those criteria is formally approved and promulgated. But now the library needs a separate document that lays out the procedures a library employee must follow in order to submit a van request. Those who have administrative oversight of library-wide policy are not usually the ones who write procedural documents; they usually assign that task to someone else (perhaps, in this case, the facilities manager).

And this is where, if you're not careful, the hijack can happen. Because in the course of prescribing procedures, the person charged with doing so is now in a position to create new requirements that are not contained in the policy itself. For example, the procedures document might require a department chair's signature, even though the policy doesn't require department chair approval of a van request. Or the policy might say that van requests must be submitted at least one week in advance, but the facilities manager might decide that for purposes of his workflow, he needs to receive the form at least two weeks in advance, and put that requirement on the form.

It's important to note that policy hijack is not always intentional – in fact, in my experience it's not usually intentional. It doesn't typically arise from someone trying to exercise bureaucratic power or undermine the authority of the library administration. I believe it usually arises because a in the course of creating a procedures document, it becomes clear that the policy as written hasn't fully accounted for all the realities of the process. In that case, policy should not be amended by means of procedure; the person charged with creating the procedure document should go back to the administration and ask for a policy revision.

How do you prevent this kind of policy hijack (whether intentional or not)? Simple: whoever has authority to approve the policy should also review any procedures documents arising from the policy, checking to make sure they stay within the boundaries of the policy before they're promulgated to the library – and then adjusting either the policy or the documents, as appropriate.

Takeaways and Action Items

• Beware of procedures documents that create shadow policies, or shadow amendments to policy.
• Avoid these by ensuring that whoever has authority to approve policy exercises oversight of procedures documents that arise from the policy.
• Assign someone (or a small group) in your library to review the procedures documents that are currently in use. Do any of them create or amend policy? If so, what needs to change – the procedures or the policies?