These are heady times for chief data officers. People in these often newly-created positions have a mandate to introduce major changes in data management and are given healthy budgets to grow teams and equip them with requisite tools. Budgets and resources, however, go only so far. Effective data management strategies must be designed to meet country-specific data governance requirements and prepare employees for the changes that will be coming their way.
A key challenge in organizational strategic design is how to address the different data governance requirements imposed by regulators in various countries. As a result, some banks are starting to appoint country-based CDOs. A bank with headquarters outside the U.S., for example, might have a single enterprise CDO in the home office to set global direction for data governance and appoint CDOs in other countries to ensure that any specific needs are understood and met.
The challenge of meeting data governance requirements is particularly complicated in the U.S. Given various operational risk incidents, anti-money laundering rules and other risk data requirements, the Federal Reserve has taken a greater interest in issues of data integrity. Data problems can have a material impact on a bank's ability to comply with many types of regulations, from capital rules to anti-money laundering laws. Having a U.S. CDO in place can help global banks ensure that their data accurately reflects their financial circumstances and risk exposure.
Data officers must also consider how best to change the way that managers and employees think about and manage critical data. Appointing managers to take formal ownership of their data can help shift bank employees' mindsets, as can establishing teams with the technical and business knowledge to proactively identify data problems and solutions.
Many banks have found that data stewardship communities are a useful tool for enabling these changes. Such communities are made up of people who can be held accountable for the quality of data that is presented to regulators and, more fundamentally, used to run the business.
Data stewardship communities include data stewards (managers responsible for educating and facilitating the key data governance tasks), data owners (executives with management accountability for data quality), data custodians (those with technical data skills) and data specialists (those with subject matter expertise).
Each one has an important role to play. They can coordinate facilitate education in data governance, helping all employees to understand concepts like "critical data" and "data lineage." This will also ensure that such concepts are built into the firm's system development approach and project lifecycle.
Data stewardship communities can also facilitate the building of a common business data glossary that includes the definitions of business terms in common use across the bank. Take the word "customer," for example. Does the term's scope include potential clients? Ensuring that these terms are commonly understood and used across a bank's business lines helps break down barriers to effective working relationships between technical and business employees.
Lastly, the data stewardship community develops, collects and reports metrics to measure progress in data quality. Once such metrics are established, bank management can assess the relative performance of different units and raise the performance bar over time.
Chief executives will provide resources and support to CDOs and their programs for only so long before they want to see a real return on their investment. Putting in place the strategies and organizational frameworks discussed here should help CDOs prepare for that reality.
Andrew Waxman writes on risk and compliance issues in capital markets. He is a consultant in IBM Global Business Services' financial markets risk and compliance practice and can be reached at email@example.com or on Twitter @abwaxman. The views expressed here are his own.