Insights — Framework
A framework for rebuilding risk governance structures where ownership has quietly drifted.
Overview
The three lines of defence model is widely adopted and, in our experience, widely eroded in practice — control ownership drifts after reorganisations without the governance documentation being updated. This framework is a structured method for rebuilding genuine ownership rather than simply re-documenting the model as it exists on paper.
Document how the three lines actually function today, not how the policy describes them.
Locate controls with no genuinely engaged owner, regardless of documented assignment.
Name specific, current owners for every identified gap.
Rebuild escalation paths around how information actually needs to move, not the formal hierarchy.
Build a recurring review cycle that catches ownership drift before it recurs.