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A good Data Governance framework should answer the following basic questions relating to data:

1. What is the process of managing data in the firm? (process, controls, structure)
2. Who is going to manage data?
3. How data is managed in the firm?
4. What happens if there are breaches to Data Management policies?

Of the four questions above, question b) i.e. who is responsible for Data Management is a very important question and the one that is most difficult to implement.

As you embark on the journey of implementing Data Governance, if you ask in any organisation as to who was responsible for a particular Data Quality issue?  The most common answer you get is “Wasn’t me!”.

Hence it is imperative to define the responsibilities of data roles as part of governance framework.

Before we dig deeper into the roles and responsibilities of data roles, we need to understand the four data roles a governance framework should have.

• Data Consumers – These are the individuals / business functions which consume the data.
• Data Custodians – A function / team / individual responsible for ensuring the technical provisioning of data
• Data Stewards – A function / team responsible to ensure that the data is of good quality
• Data Owners / Champions / Sponsors – A business function / team that’s retains the ultimate accountability for the data.

Identification of Data Owners is crucial to a successful Data governance program.   Let me share with you three killer questions to identify a Data Owner.

1. Does the function input / create / master / author the data? For example in an investment bank, the traders input the trade details, hence should be considered as the Owners of such data.   There could be occasions where such activities are delegated to another business function.
2. Does the function act as ultimate approver for the creation of data? 

   In certain occasion, a particular business function may not create or input such data, however act as an approver.  For example, a customer data may be keyed in by a client on-boarding team; however the data is approved by a customer relationship team which then gets stored in a database. In such cases, the customer relationship team could be assigned as the owner.

3. Does the function sign off on material contracts / agreements relate to data?
   Another scenario is where a data is externally sourced from a vendor, in such cases a particular function act as a key signatory on the selection of the vendor and challenges the accuracy of the data provided by the vendor.  For example, an organisation may source FX rates for their analysis from an external provider.  The selection of the vendor was based on a number of criteria, including a validation and approval by Finance. In such cases, Finance could be considered as Data Owner.

I have been made aware of cases, where data ownership assignment has taken months.  However it is critical that all the parties discuss and arrive at a conclusion of Data Owner, as the Data Owner retains the ultimate accountability for the data that they own.