Tag Archives: information governance

Are You Looking For A New Information Governance Framework?

A few months ago, while addressing a room full of IT and business professional at an Information Governance conference, a CFO said – “… if we designed our systems today from scratch, they will look nothing like the environment we own.” He went on to elaborate that they arrived there by layering thousands of good and valid decisions on top of one another.

Similarly, Information Governance has also evolved out of the good work that was done by those who preceded us. These items evolve into something that only a few can envision today. Along the way, technology evolved and changed the way we interact with data to manage our daily tasks. What started as good engineering practices for mainframes gave way to data management.

Then, with technological advances, we encountered new problems, introduced new tasks and disciplines, and created Information Governance in the process. We were standing on the shoulders of data management, armed with new solutions to new problems. Now we face the four Vs of big data and each of those new data system characteristics have introduced a new set of challenges driving the need for Big Data Information Governance as a response to changing velocity, volume, veracity, and variety.

Information GovernanceDo you think we need a different framework?

Before I answer this question, I must ask you “How comprehensive is the framework you are using today and how well does it scale to address the new challenges?

While there are several frameworks out in the marketplace to choose from. In this blog, I will tell you what questions you need to ask yourself before replacing your old framework with a new one:

Q. Is it nimble?

The focus of data governance practices must allow for nimble responses to changes in technology, customer needs, and internal processes. The organization must be able to respond to emergent technology.

Q. Will it enable you to apply policies and regulations to data brought into the organization by a person or process?

  • Public company: Meet the obligation to protect the investment of the shareholders and manage risk while creating value.
  • Private company: Meet privacy laws even if financial regulations are not applicable.
  • Fulfill the obligations of external regulations from international, national, regional, and local governments.

Q. How does it Manage quality?

For big data, the data must be fit for purpose; context might need to be hypothesized for evaluation. Quality does not imply cleansing activities, which might mask the results.

Q. Does it understanding your complete business and information flow?

Attribution and lineage are very important in big data. Knowing what is the source and what is the destination is crucial in validating analytics results as fit for purpose.

Q. How does it understanding the language that you use, and can the framework manage it actively to reduce ambiguity, redundancy, and inconsistency?

Big data might not have a logical data model, so any structured data should be mapped to the enterprise model. Big data still has context and thus modeling becomes increasingly important to creating knowledge and understanding. The definitions evolve over time and the enterprise must plan to manage the shifting meaning.

Q. Does it manage classification?

It is critical for the business/steward to classify the overall source and the contents within as soon as it is brought in by its owner to support of information lifecycle management, access control, and regulatory compliance.

Q. How does it protect data quality and access?

Your information protection must not be compromised for the sake of expediency, convenience, or deadlines. Protect not just what you bring in, but what you join/link it to, and what you derive. Your customers will fault you for failing to protect them from malicious links. The enterprise must formulate the strategy to deal with more data, longer retention periods, more data subject to experimentation, and less process around it, all while trying to derive more value over longer periods.

Q. Does it foster stewardship?

Ensuring the appropriate use and reuse of data requires the action of an employee. E.g., this role cannot be automated, and it requires the active involvement of a member of the business organization to serve as the steward over the data element or source.

Q. Does it manage long-term requirements?

Policies and standards are the mechanism by which management communicates their long-range business requirements. They are essential to an effective governance program.

Q. How does it manage feedback?

As a companion to policies and standards, an escalation and exception process enables communication throughout the organization when policies and standards conflict with new business requirements. It forms the core process to drive improvements to the policy and standard documents.

Q. Does it Foster innovation?

Governance must not squelch innovation. Governance can and should make accommodations for new ideas and growth. This is managed through management of the infrastructure environments as part of the architecture.

Q. How does it control third-party content?

Third-party data plays an expanding role in big data. There are three types and governance controls must be adequate for the circumstances. They must consider applicable regulations for the operating geographic regions; therefore, you must understand and manage those obligations.

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Keeping Information Governance Relevant

Gartner’s official definition of Information Governance is “…the specification of decision rights and an accountability framework to encourage desirable behavior in the valuation, creation, storage, use, archival and deletion of information. It includes the processes, roles, standards, and metrics that ensure the effective and efficient use of information in enabling a business to achieve its goals.” It therefore looks to address important considerations that key stakeholders within an enterprise face.

A CIO of a large European bank once asked me – “How long do we need to keep information?”

Keeping Information Governance relevant

Data-Cartoon-2This bank had to govern, index, search, and provide content to auditors to show it is managing data appropriately to meet Dodd-Frank regulation. In the past, this information was retrieved from a database or email. Now, however, the bank was required to produce voice recordings from phone conversations with customers, show the Reuters feeds coming in that are relevant, and document all appropriate IMs and social media interactions between employees.

All these were systems the business had never considered before. These environments continued to capture and create data and with it complex challenges. These islands of information that seemingly do not have anything to do with each other, yet impact how that bank governs itself and how it saves any of the records associated with trading or financial information.

Coping with the sheer growth is one issue; what to keep and what to delete is another. There is also the issue of what to do with all the data once you have it. The data is potentially a gold mine for the business, but most businesses just store it and forget about it.

Legislation, in tandem, is becoming more rigorous and there are potentially thousands of pieces of regulation relevant to multinational companies. Businesses operating in the EU, in particular, are affected by increasing regulation. There are a number of different regulations, including Solvency II, Dodd-Frank, HIPAA, Gramm-Leach-Bliley Act (GLBA), Basel III and new tax laws. In addition, companies face the expansion of state-regulated privacy initiatives and new rules relating to disaster recovery, transportation security, value chain transparency, consumer privacy, money laundering, and information security.

Regardless, an enterprise should consider the following 3 core elements before developing and implementing a policy framework.

Whatever your size or type of business, there are several key processes you must undertake in order to create an effective information governance program. As a Business Transformation Architect, I can see 3 foundation stones of an effective Information Governance Program:

Assess Your Business Maturity

Understand the full scope of requirements on your business is a heavy task. Assess whether your business is mature enough to embrace information governance. Many businesses in EMEA do not have an information governance team already in place, but instead have key stakeholders with responsibility for information assets spread across their legal, security, and IT teams.

Undertake a Regulatory Compliance Review

Understand the legal obligations to your business are critical in shaping an information governance program. Every business is subject to numerous compliance regimes managed by multiple regulatory agencies, which can differ across markets. Many compliance requirements are dependent upon the numbers of employees and/or turnover reaching certain limits. For example, certain records may need to be stored for 6 years in Poland, yet the same records may need to be stored for 3 years in France.

Establish an Information Governance Team

It is important that a core team be assigned responsibility for the implementation and success of the information governance program. This steering group and a nominated information governance lead can then drive forward operational and practical issues, including; Agreeing and developing a work program, Developing policy and strategy, and Communication and awareness planning.

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Posted in Data Governance, Financial Services, Governance, Risk and Compliance | Tagged , , , , , | 1 Comment

Unique Identification and Unique Identifiers

A major challenge in data quality and in master data management is the ability to uniquely identify a specific entity and/or differentiate one entity from another.  In a perfect world, we would be able to depend on three assertions to simplify the task: (more…)

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