I think there may be some confusion; our clean desk policy isn't a stand alone policy, it's only one small component of our Customer Information Program and Policy. The clean desk checklist is only one way that the monitoring and certification is accomplished for compliance with the program. In our institution, inspections are performed by each department or branch manager who sign off the certifications and then give them to the compliance officer who then in turn reports the results to the Board in the annual Customer Information Security status report. We chose to do the inspection monthly, on recommendation by our examiners. Exceptions are noted on the monthly certification and are in turn reported to the Audit Committee of the board.
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