Purpose
Provide assurance that recurring and specialist training is current, assigned, delivered, assessed and completed at the required frequency.
Objective
Ensure all personnel complete annual refreshers, high-risk functions complete semiannual training and affected personnel receive timely event-driven updates.
Normative
Compliance and Department Heads shall monitor recurring and role-specific training to completion and escalate overdue, unsuccessful or materially delayed assignments.
Descriptive
The control uses the enterprise TRAIN process for assignment and evidence while relying on domain owners for accurate AML, sanctions, cyber, continuity, privacy, finance, conduct, safeguarding and other specialist content. Specialized training shall be proportionate to the role and refreshed as necessary when responsibilities, systems, or risk exposures materially change. Where policy or tool changes materially affect control operation, targeted refresher training or operational guidance shall be delivered without waiting for the next annual cycle. Ongoing training reinforces updates to laws, regulations, and internal policies; changes in Bitkaya’s risk profile or control environment; lessons learned from incidents, findings, control failures, or near misses; changes to systems, onboarding tools, screening tools, monitoring tools, or workflows; and practical expectations regarding escalation, documentation, client treatment, and control compliance.
Evidence
- Expected evidence: Required population and assignment report
- Expected evidence: Approved material version and trainer record
- Expected evidence: Attendance, completion and knowledge-check results
- Expected evidence: High-risk semiannual and all-personnel annual completion reconciliation
- Expected evidence: Material-change training record and overdue escalation
- Evidence location: source evidence in SYS-ECM-002 Compliance Reporting and Evidence Repository; target Hermes assessment record in Odoo under ISS-HERMES-001.
- Retention: according to the applicable approved policy and Bitkaya record-retention requirements.
- Testing method: reconcile the required population and a sample of material changes to timely assignment, completion and assessment
- Testing frequency: quarterly
Assurance
Runtime effectiveness results are maintained in Odoo and assessed through the Hermes workflow tracked in ISS-HERMES-001. This note defines design, ownership, evidence expectations and testing method; it does not contain a manually maintained operation, evidence or overall effectiveness rating.
- Design status: implemented
Assurance Assertions
- All personnel receive annual refresher training.
- High-risk functions receive semiannual training.
- Material changes trigger targeted training without waiting for the next cycle.
- Completion and knowledge checks are evidenced and overdue items escalated.
Relationships
- Policy: POL-TRAIN-001 Training and Awareness Manual
- Process: PRC-RSA-001 Resilience Systems and Assurance
- Procedure: PROC-TRAIN-003 Deliver Recurring and Role Specific Training
History
- 2026-07-26: Normalized evidence metadata and separated design status from runtime effectiveness.
- 2026-07-26: Created from the approved Training & Awareness Manual version 1.1.