PMM That Collects Without Acting Is Non-Compliant Article 72 requires a PMM system that “actively and systematically” collects, documents, and analyses data. A system that collects data but does not act on it is non-compliant with the spirit of Article 72. The PMM system is the mechanism through which the organisation detects problems not anticipated during development, identifies drift developing over time, gathers evidence for serious incident reports, and generates data feeding back into the risk management system. The feedback loop, the escalation framework, and the quarterly governance review are the mechanisms that ensure PMM findings translate into actions. Without these mechanisms, monitoring dashboards become decoration and compliance reports become fiction. A competent authority assessing the organisation’s PMM compliance will examine not only whether monitoring is operational, but whether findings have produced changes. A PMM system with no documented actions over twelve months, despite operating in a dynamic production environment, suggests either that the monitoring is not detecting issues (a sensitivity problem) or that detected issues are not being addressed (a governance problem). Key outputs

• Active and systematic collection, analysis, and action required
• Feedback loop, escalation, and governance review as action mechanisms
• Authority scrutiny extends to whether findings produced changes
• Module 12 AISDP documentation