GRC Policy Exceptions in ServiceNow GRC

[Sathya-Kalyani]

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Understanding Policy Exceptions in ServiceNow GRC

Organizations implement policies and controls to maintain compliance with internal standards and external regulations. However, there may be situations where users are temporarily unable to meet these compliance requirements. In such cases, Policy Exceptions in ServiceNow GRC provide a structured way to document, review, and approve temporary deviations from policies or controls.

This article explains what policy exceptions are, when they should be used, and how their lifecycle works in ServiceNow.

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What is a Policy Exception?

A Policy Exception is a temporary approval granted when a user or system cannot comply with a specific policy, control objective, or control requirement due to exceptional circumstances.

Policy exceptions help organizations stay aware of compliance gaps while still managing associated risks in a controlled and documented manner.

Example

For example, a policy may require that all critical operating system servers must be patched within 48 hours after a vendor releases patches. If a system cannot be patched within this timeframe due to operational constraints, a policy exception can be requested for that system until the issue is resolved.

Policy exceptions are generally intended as short-term solutions, typically granted for a limited duration such as 30 or 90 days. The request goes through an approval process that may involve multiple stakeholders, such as compliance managers or control owners. Once approved, the affected control is marked as “Compliant with Exception” until the exception expires.

If the issue is not resolved before the expiration date, the requester can request an extension, which will again go through the approval process.

It is important to note that policy exceptions are meant for temporary situations. If compliance cannot be achieved in the long term—such as when legacy systems or strategic business decisions prevent compliance—organizations may choose Risk Acceptance, where management formally acknowledges and accepts the associated risk.

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When Should Policy Exceptions Be Used?

Policy exceptions should be used when:

• Compliance cannot be achieved temporarily.
• There is a valid business or technical reason for the deviation.
• The situation is expected to be resolved within a short period.

In most cases, policy exceptions are granted for short durations such as 30 or 90 days, with the possibility of extensions if required.

For long-term or permanent non-compliance scenarios, organizations should instead consider Risk Acceptance, where the risk is formally acknowledged and approved by management.

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Policy Exception Lifecycle

The lifecycle of a policy exception typically includes the following steps:

Request Creation
A requester, usually the control owner, raises a policy exception and provides details such as the reason, justification, impacted controls, and the requested duration.

Review and Analysis
The exception request is reviewed, and a risk assessment may be conducted to evaluate the potential impact and likelihood of the risk.

Approval Process
The request moves through a multi-level approval workflow involving relevant stakeholders.

Approval Outcome
Once approved, the affected control is marked as “Compliant with Exception” in the compliance framework until the exception expires.

Monitoring and Expiry
The exception remains active until the specified Valid To date. If the issue is not resolved before this date, the requester may submit a request for an extension.