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agile42 | We advise, train and coach companies building software www.agile42.com | All rights reserved. Copyright ©2007-2014. Is agile compliance an oxymoron? @davesharrock

IBM Innovate2014 - Is Agile Compliance an Oxymoron?

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Agile software development is a light framework that focusses more on early value delivery and incremental improvement than traditional tasks like detailed up-front planning, comprehensive specifications and technical documentation. But from the perspective of regulatory compliance, this planning and documentation serve a purpose. How can we reconcile agile approaches that value a working product over documentation with the need to meet regulatory requirements for, e.g. medical devices or telecommunications? I will discuss how to bring together the apparently conflicting needs of regulatory compliance and agile, and show by example how agile teams actually approach tough regulatory requirements in finance, healthcare and telecommunications. Learning Objectives - How to use agile in a highly-regulated environment - How to incorporate strict regulatory requirements within an agile development approach - The power of agile as a risk-limiting software development approach

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Page 1: IBM Innovate2014 - Is Agile Compliance an Oxymoron?

agile42 | We advise, train and coach companies building software www.agile42.com | All rights reserved. Copyright ©2007-2014.

Is agile compliance an oxymoron?

@davesharrock

Page 2: IBM Innovate2014 - Is Agile Compliance an Oxymoron?

agile42 | We advise, train and coach companies building software www.agile42.com | All rights reserved. Copyright ©2007-2014.

compliance international B2B MBA English IPO

agile husband start-up technology

newly-minted Canadian ITexecutive leanstartup outsourcing father

enterprise transitionsB2C data analysis kanban seismology PhD

scrum geophysicistorganizational excellence

Certified Scrum Trainer® (CST)Certified Scrum Coach (CSC)[email protected]: @davesharrockwww.facebook.com/agile42

Dr Dave Sharrock

Page 3: IBM Innovate2014 - Is Agile Compliance an Oxymoron?

agile42 | We advise, train and coach companies building software www.agile42.com | All rights reserved. Copyright ©2007-2014.

Why Agile?

Page 4: IBM Innovate2014 - Is Agile Compliance an Oxymoron?

agile42 | We advise, train and coach companies building software www.agile42.com | All rights reserved. Copyright ©2007-2014.

Growing Software Complexity

Software complexity in FORD vehicles quadruplicated in 5 years

0

2.5

5

7.5

10

2005 2006 2007 2008 2009 2010

10

6

4.5

3.42.8

2.4

Software lines in FORD vehicles over 5 years

x4

MLOC in Ford vehicles

Page 5: IBM Innovate2014 - Is Agile Compliance an Oxymoron?

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Increasing Complexity in Technology Environments

Language types and versions released per decade, taken from O’Reilly’s Programming Language Timeline

0

22

44

66

88

110

1954-1959 1960-1964 1965-1974 1975-1984 1985-1994 1995-2004

104

5041

25

1211

New programming languages and versions released

x10

Page 6: IBM Innovate2014 - Is Agile Compliance an Oxymoron?

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Time to MarketDue to globalization effects, and other economical changes, the time to market over time decreased significantly

Deepa Chandrasekaran, Gerard J. Tellis - Marshall School of Business, University of Southern California, Los Angeles, California

1915 1939 1972 1976 1983 1994 1998 2000 2002 2004

13.5 years

3 months

Mean time to take-off

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Agile projects are 3x more successful than non-agile projects*

The report goes so far as to say, “The agile process is the universal remedy for software development project failure. Software applications developed through the agile process have three times the success rate of the traditional waterfall method and a much lower percentage of time and cost overruns.” (page 25)

* According to the 2011 CHAOS report from the Standish Group

The Standish Group defines project success as:• on time• on budget• with all planned features

Page 8: IBM Innovate2014 - Is Agile Compliance an Oxymoron?

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Why does that matter?

Page 9: IBM Innovate2014 - Is Agile Compliance an Oxymoron?

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Defined Process ControlThe time required to complete a repeatable action is a valid proxy to predict time to complete

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Empirical Process ControlEvery step performed while creating a new product is unique, only outcome can be trusted

Page 11: IBM Innovate2014 - Is Agile Compliance an Oxymoron?

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And compliance?

Page 12: IBM Innovate2014 - Is Agile Compliance an Oxymoron?

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Why should it be more difficult to apply Agile where IT governance & regulatory compliance is enforced?

Page 13: IBM Innovate2014 - Is Agile Compliance an Oxymoron?

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We only listen to the cool kids at school

https://www.flickr.com/photos/jordyn-tacozombie/5555279358/

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Our intuitive response is to increase control

We only listen to the cool kids at school

https://www.flickr.com/photos/cmdrcord/

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Our intuitive response is to increase control

We only listen to the cool kids at school

Compliance too often bad cop, not good referee

https://www.flickr.com/photos/clydeorama/

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what is governance and regulatory compliance?

Page 17: IBM Innovate2014 - Is Agile Compliance an Oxymoron?

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Goals of IT Governance & Regulatory Compliance

The primary goals for information technology governance are to: 1. Assure that investment in IT generates business value, and 2. Mitigate the risks associated with IT

Primary goals of regulatory compliance1. Meet federal or industry minimum standards2. Typically breakdown into:

• Work Authorization• Segregation of Duties• Process Change Control• Audit Support

Page 18: IBM Innovate2014 - Is Agile Compliance an Oxymoron?

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Comparing the goals

1234

QualityProductivityPredictabilityBusiness Value

Business ValueRisk Management

Effectiveness

Exceed requirements

governance agility

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Interpreted to be prescriptive

"The system by which the current and future use of ICT is directed and controlled. It involves evaluating and directing the plans for the use of ICT to support the organisation and monitoring this use to achieve plans. It includes the strategy and policies for using ICT within an organisation."

Australian Standard

"… the leadership and organisational structures and processes that ensure that the organisation’s IT sustains and extends the organisation’s strategies and objectives"

IT Governance Institute

“The structure, oversight and management processes which ensure the delivery of the expected benefits of IT in a controlled way to help enhance the long term sustainable success of the enterprise.”

ISACA

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Achieving agility vs. compliance

Communica)on

Empowerment

Transparency

Adaptability

Itera)ve  &  Incremental

Defined  Process  &  Standards

Plan  ›  Analyze  › Develop  › TestTraceability

Formal  review  and  approval

Configura)on  Management

governance agility

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how to reconcile agile and governance processes

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Agile delivery

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The wrong way to deliver agile compliance

0

1

2

3

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Scrum process

1.  Interac)on

2.  Documenta)on

3.  Automa)on

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Interaction

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CONCEIVE DESIGN IMPLEMENT DEPLOY

A typical product development process

time-to-market

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CONCEIVE DESIGN IMPLEMENT DEPLOY

valueadding

non-valueadding

Mapping the value stream

time-to-market

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CONCEIVE DESIGN IMPLEMENT DEPLOY

valueadding

non-valueadding

Common non-value adding steps include...

time-to-market

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Merging agile and compliance needs

Interac(on• Role  of  involved  stakeholder• Defines  minimum  requirements  to  be  met

• Reviews  Requirements  &  User  Stories

• Provides  reviews/direc)on  within  Sprint

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Documentation

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Is documentation waste?

“Everything that does not add value to the product is waste”

1st  principle  of  lean  development

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Is documentation waste?

“If you must produce paperwork that adds little customer value, there are three rules to remember: Keep it short. Keep

it high level. Do it offline.”

“Safety-critical systems are frequently regulated and are often required to have written requirements, traceable to

code. In this case, formatting the requirements so that they can easily be evaluated and checked for completeness may qualify as a value-adding activity. Look for a table driven or template driven format that reduces the requirements to a

condensed format that both users and development can rapidly understand and validate.”Mary Poppendieck, Lean Software Development

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Changing role of specifications

RequirementsSpecifica(ons

Design

Code

Tests

Requirements  Specifica)ons  drive  implementa)on

Requirements  document  system  as-­‐built

Requirements  Specifica(ons

Epics

User  StoriesAcceptance  Criteria

Design

Code

Validate  /Update

Define  /Execute

Tests

governance agility

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Changing role of standard operating procedures

Standards  reduce  varia)on  and  allow  untrained  people  to  make  decisions.

WriPen  standards  are  to  be  followed,  not  changed.

A  Standard  defines  goals  for  a  team  to  reach,  and  constraints  to  observe.  

An  Agile  Team  will  use  it  as  a  baseline  for  con)nuous  process  improvement.

governance agility

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Changing role of document review and approval

This  document  is  now  approved  as  input  for  the  next  development  phase.  

This  document  is  now  part  of  a  consistent  product  increment.

The  Defini)on  of  Done  and  Defini)on  of  Ready  allow  seSng  of  minimal  requirements  to  pass  to  

the  next  phase.

governance agility

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Lean Canvases... What?

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Lean Portfolio Canvas™ have been created by agile42 and are licensed using Creative Common 3.0 with attribution (by), non commercial usage (nc) and share alike (sa) options. You can reuse and modify the template, but you will always have to leave the logo on it

Feature Name (title)

1. Opportunity 2. Customer SegmentsWhat is the problem to be solved? What type of customers & users will

benefit from this solution?

How is the customer solving the problem right now?

3. Possible SolutionWhat are the key points of a possible solution to the presented problem?

4. BenefitsWhat are the benefits for the customers?

What are the benefits for internal stakeholders?

6. Measuring SuccessWhat metrics will be best measure the success of the feature?

5. Business ReadinessWhat steps are required from the business side to be able to use this capability?

7. Cost of DelayWhich profile better represent the cost of delay (CoD)?

8. Costs StructureHow does the cost structure look like for such a feature? One time, ongoing costs, contractors expenses, development costs?

9. Value to Customer and BusinessWhat are the expected incremental revenue for selling this feature, and what are the strategic and tactical benefit? What are the intangible values (usability, performance, customer knowledge obtained...)

It will contain 5000 songs

Current digital music player can only hold up to 20 songs

Re-sync their music frequently

- Jogging lovers- Bicycle riders- Music

Professionals

- media store 1000+ songs

- fit in a pocket- compression

- no need to sync often

- change mood change song

- playlists

- addressing a new market

- micro engineering

- partnership with component builder

- sales channels- Packaging- Agreement with

Music Firms?

- Hardware development cost- SKU costs target $170.00- 3rd parties licenses for digital

music

- Usability with one hand- Long battery life- All songs you own in one place

- store 1000 songs (HQ)

- 1000 early adopters/week on 1st monthHow Can

we test

this?

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Minimal Viable Product

Experiment with Target

Consolidate learnings

Evolve

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Do we understand and agree on WHAT are the needs?

A Lean Canvas serves as a container to represent a specific need, and allow to have a structured conversation with the stakeholders, and agree on the objectives…

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Merging agile and governance needs

Documenta(on• Document  system  as-­‐built

• Opera)ng  procedures  serve  as  baseline

• DoR,  DoD  serve  as  minimal  requirements

• Document  is  part  of  product  increment

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Automation (or DevOps)

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Source InspectionPoka-Yoke

(Error-Proofing)

Information Inspection

Jidoka (Automation)

Judgement InspectionDr. Shigeo Shingo, co-

creator of the TPS

Avoid Errors

Find Errorsbefore they become defects

Find Defects

Different types of inspection

Page 43: IBM Innovate2014 - Is Agile Compliance an Oxymoron?

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ATDD

Unit testsComponentIntegration

tests

Performance security, load

testing

Exploratory & Usability testing UAT

Q2

Q1

Q3

Q4

Business-facing

Technology-facing

Supp

ort t

he te

am

Critiq

ue th

e pr

oduc

tCopyright  2009  Lisa  Crispin,  Janet  Gregory

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ATDDakaBDDaka

Story-testing

Business-facing

Supp

ort t

he te

am

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Write code to pass the test

Add an acceptance test

Fails?

Acceptance test passes?

Acceptance Test Driven Development

Page 46: IBM Innovate2014 - Is Agile Compliance an Oxymoron?

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Undefined

Undefined

Undefined

- I want to be able to sync a song with a click

Acceptance Test #1

Step 1 Step 2 Step 3X X V XV V

V- I want to add the song to my “Favorite” playlist UndefinedUndefined

Acceptance Test #2

Step 1 Step 2VVVDone!

Done is not an opinion ;-)

Page 47: IBM Innovate2014 - Is Agile Compliance an Oxymoron?

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Agile Engineering Practices

Delivering fast requires new methods... and new tools

People need to learn new tools and new practices...

Page 48: IBM Innovate2014 - Is Agile Compliance an Oxymoron?

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Add a test

Run the test & check failure

Write code to pass the test

Run tests see all pass

Re-Factor

Re-Test

Test Driven Development

Page 49: IBM Innovate2014 - Is Agile Compliance an Oxymoron?

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TDD

Cyc

leAdd an

acceptance test

Fails?

Acceptance test passes?

Add a test

Run the test & check failure

Write code to pass the test Run tests see all pass

Re-Factor

Re-Test

ATDD + TDD

Page 50: IBM Innovate2014 - Is Agile Compliance an Oxymoron?

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“Inspection to find defects is waste, inspection to prevent defects is essential”

“If you find bug regularly, you have got a defective process”

Mary Poppendieck, Google Talk “Competing on the basis of speed” Dec. 15, 2006

Defects are symptoms of a poor process

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Agile Compliance is...

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Cucumber – Process Validation – Why?

Dr. Christian BeckScrumMed 2013

“Any software used to automate any part of the device production process or any part of the quality system

must be validated for its intended use, as required by 21 CFR §820.70(i). This requirement applies to any software used to automate device design, testing,

component acceptance, manufacturing, labeling, packaging, distribution, complaint handling, or to

automate any other aspect of the qualitysystem. FDA General Guidelines on Software Validation“

FDA General Guidelines on Software Validation

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Goals – Values - Principles

Principles stated in DIN62304, GGoSV, Design Control Guidance* Agile Principles & Practices

Conduct V&V throughout the SW dev lifecycle Incremental & Iterative Development

Ensure consistency of design artifacts Limit WIP, „Potentially Shippable“

Configuration Management / Document Control Configuration Management

Design input requirements are the result of the first stage of the design control process Backlog Grooming

Design input requirements should specify what the design is intended to do while carefully avoiding specific design solutions at this stage

User Stories / Acceptance Criteria

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Principles stated in DIN62304, GGoSV*, Design Control Guidance** Agile Principles & Practices

Traceability Limit WIP

Procedures (Standardization) Working Agreements / 5S

Create Evidence (Auditability) -

Independence of Review „multidimensional testing“

*General Guidelines for Software Validation**Design Control Guidance for Medical Device Manufacturers

Goals – Values - Principles

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Reader 1 Reader 2 Decision

- - „Well letter“

+ - ! Consensus Conf.

- + ! Consensus Conf.

+ + Recall

The quality of decision is achieved by

collaboration and and skillful integration of

different mental models

Example: Mammography Screening

Independent Review

Collaborative Problem Solving

Independence of Review

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The value of compliance is...

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falling defect rates...

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and less time ‘hardening’ the product

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In conclusion

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Conclusions• Agility and IT Governance & Regulatory

Compliance share the same objectives

• Differences in HOW they are implemented drives potential conflict

• Agility and Compliance can co-exist:

• Involve Compliance as involved Stakeholder, providing reviews/direction within Sprint

• Deliver compliance documentation as part of product increment, codified within DoD and automated tests

• Automate change tracking to reduce compliance burden, and provide comprehensive oversight

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More food for thought...

http://www.slideshare.net/davesharrock

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Thank you

[email protected]@davesharrock

facebook.com/agile42

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