I am hearing from some scheme owners and advocates for certification that they want auditors to help out the folks they are auditing by providing them with advice on how to fix the problems that the certification client is facing.
Under ISO, ISEAL and IAF approaches to auditing, impartiality is one of the highest values. The audit should be not benefit the auditor, the certification body or anyone that either the auditor or the certification body have an interest in gaining a benefit for. The goal should be to provide high quality, professional and impartial audit services. A certification decision should be based on the information gathered in the audit and nothing else.
Impartiality is maintained when there is no real or perceived conflict of interest that would lead a reasonable person to believe that an audit decision may be taken for any reason other than the audit evidence as observed by the auditor and a decision based on that evidence by the certification body. On the most obvious level it means that the auditor should not have other business with the certification client or have provided any products or services to the client within a set amount of time before the audit (IAF sets a minimum of 2 years, other schemes have differing rules).
A key factor to consider in understanding impartiality is that the auditor should not under any circumstance be evaluating a product or service that he provided. First, she may be tempted to approve her own work because it looks better on her. Secondly, he may feel that since his work or product is in use that all is well and not properly evaluate how it is working.
Certification bodies are required to have a decision making entity that is independent from the part of the certification body that is responsible for or directly benefits from revenue generation. So for example a CEO of a certification body would normally not be involved with a certification decision since her job is to increase the revenue to the company. The decision makers must be individuals that neither benefit from or be penalized for a particular decision.
Providing advice to a client on how to best meet the requirements of a standard can lead to a number of conflicts of interest. For example, an auditor may try to sell her consulting services to the client and a client may feel pressured to hire the auditor out of fear that the client may fail the audit if they do not.
Also, a client may feel pressured to do what the auditor suggests even if it does not solve the problem or does not otherwise fit the needs of the client. This could mean installing equipment that is not fully compatible or spending more money than the client can afford.
If the client does what the auditor suggests and it does not work, how will the auditor provide an impartial audit when he returns? Will she feel the need to minimize the problems? Will he feel responsible and want to avoid costing the client more money by giving a negative recommendation?
Certification bodies that provide services for schemes that require full impartiality may not want to provide services for schemes that want auditors to provide advice since it may complicate the certification body's own efforts to maintain clear and consistent rules for impartiality.
Any scheme that wants to design a program that includes auditors providing advice to clients will need to think through the implications for impartiality. How would you give advice and still conduct an impartial audit?
Another challenge is that some of the best auditors may be in fact really lousy at giving advice. They are trained as auditors to evaluate whether or not the requirements are being met, they may not be very good at recommending how to solve a problem and produce the result that the scheme requires. The same may be the case for the reverse, a really good problem solver may be a really lousy auditor.
One possible implication is that a scheme may become more expensive to clients since the auditors not only have to be top notch auditors but they also have to be great at coming up with solutions.
Finally, how would you design your program to make sure that the clients feel no pressure to implement the solution proposed by the auditor? Maybe there is a better, cheaper, and more effective solution available that may not be used.
The rules against auditors providing advice are in place for good reasons, because they solve real world problems. Any scheme that wants to change these rules will need to find another way to solve these real problems that does not just create new ones.