1 Copyright © 2015 Robert S. Seiner – KIK Consulting & Educational Services / TDAN.com Copyright © 2015 Robert S. Seiner – KIK Consulting & Educational

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Copyright © 2015 Robert S. Seiner – KIK Consulting & Educational Services / TDAN.comCopyright © 2015 Robert S. Seiner – KIK Consulting & Educational Services / TDAN.com

Non-Invasive Data Governance™Non-Invasive Data Governance™ is a trademark of Robert S. Seiner & KIK Consulting is a trademark of Robert S. Seiner & KIK Consulting

Robert S. SeinerRobert S. SeinerKIK Consulting & Educational Services – KIKconsulting.comKIK Consulting & Educational Services – KIKconsulting.com

The Data Administration Newsletter – TDAN.comThe Data Administration Newsletter – TDAN.com

Formalization of Data StewardshipFormalization of Data Stewardshipto Succeed in Data Governanceto Succeed in Data Governance

Non-Invasive Data Governance™Non-Invasive Data Governance™Presentation for DAMA NY – DAMA Day 2015Presentation for DAMA NY – DAMA Day 2015

May 21, 2015May 21, 2015

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• Non-Invasive Data Governance:Non-Invasive Data Governance:The Path of Least Resistance and Greatest SuccessThe Path of Least Resistance and Greatest Success–ISBN 9781935504856 / Technics PublishingISBN 9781935504856 / Technics Publishing–Published September 2014Published September 2014

• KIKConsulting.comKIKConsulting.comHome of Non-Invasive Data Governance™Home of Non-Invasive Data Governance™Completely Refurbished Web-SiteCompletely Refurbished Web-Site–Live June 2014Live June 2014

• Real-World Data Governance Webinar SeriesReal-World Data Governance Webinar SeriesEverybody is a Data Steward; Get Over ItEverybody is a Data Steward; Get Over It–Live Webinar on Thursday, June 18 at 2pm ESTLive Webinar on Thursday, June 18 at 2pm EST–Register @ DATAVERSITY.netRegister @ DATAVERSITY.net

Formalization of Data StewardshipFormalization of Data StewardshipWhat’s New?What’s New?

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• The governance of data is already taking place in your organization. The same The governance of data is already taking place in your organization. The same thing can be said for the stewardship of data – albeit in a mostly informal, thing can be said for the stewardship of data – albeit in a mostly informal, inefficient and ineffective manner. inefficient and ineffective manner.

• Non-Invasive Data Governance Non-Invasive Data Governance focuses on the formalization of accountability focuses on the formalization of accountability and the application of governance to existing and / or new processes as a less and the application of governance to existing and / or new processes as a less threatening approach. threatening approach.

• In this session Bob Seiner will share his “everybody is a data steward” concept In this session Bob Seiner will share his “everybody is a data steward” concept and how it may be the key to program success. and how it may be the key to program success.

Formalization of Data StewardshipFormalization of Data StewardshipAbstractAbstract

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• Bob will talk about how to formalize existing levels data governance and data Bob will talk about how to formalize existing levels data governance and data stewardship as a way to start a new program and how to benefit from this stewardship as a way to start a new program and how to benefit from this concept to enhance an existing program. concept to enhance an existing program.

• The topics he will address include:The topics he will address include:– Concepts of a Non-Threatening ApproachConcepts of a Non-Threatening Approach– 8 Rules for Becoming a Data Steward8 Rules for Becoming a Data Steward– Different Levels of StewardsDifferent Levels of Stewards– Formalizing Governance Through ProcessFormalizing Governance Through Process– The Data Governance Bill of “Rights”The Data Governance Bill of “Rights”

Formalization of Data StewardshipFormalization of Data StewardshipAbstractAbstract

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• Data GovernanceData Governance– Data Governance is the Data Governance is the Execution and Enforcement of AuthorityExecution and Enforcement of Authority

Over the Definition, Production & Usage of Data and Data-Related Resources.Over the Definition, Production & Usage of Data and Data-Related Resources.

Formalization of Data StewardshipFormalization of Data StewardshipDefinitionsDefinitions

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• Data StewardshipData Stewardship– Data Stewardship is the Data Stewardship is the Formalization of AccountabilityFormalization of Accountability

Over the Definition, Production & Usage of Data and Data-Related Resources.Over the Definition, Production & Usage of Data and Data-Related Resources.


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• Potential Definitions of Data GovernancePotential Definitions of Data Governance– Data Governance is formalization of repeatable process for managing data as it Data Governance is formalization of repeatable process for managing data as it

progresses throughout the Data Lifecycle cradle to grave; namely to support:progresses throughout the Data Lifecycle cradle to grave; namely to support:• Master Data Management / Business Intelligence / Enterprise View of DataMaster Data Management / Business Intelligence / Enterprise View of Data• Data Integration / ERP / Package ImplementationData Integration / ERP / Package Implementation• Risk Management / Data Protection / ComplianceRisk Management / Data Protection / Compliance

– Data Governance is the formalization of behavior and accountability associated Data Governance is the formalization of behavior and accountability associated with management of data and data-related assets.with management of data and data-related assets.


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• Non-Invasive Data Governance™Non-Invasive Data Governance™– The practice of:The practice of:

• applying formal accountability & behavior applying formal accountability & behavior • through a non-invasive framework of roles & responsibilitiesthrough a non-invasive framework of roles & responsibilities• to existing and / or new processesto existing and / or new processes• to assure that the definition, production & usage of datato assure that the definition, production & usage of data• guarantee regulatory compliance, security, privacy, protection & quality.guarantee regulatory compliance, security, privacy, protection & quality.

– Non-Invasive describes how governance is applied to assureNon-Invasive describes how governance is applied to assurenon-threatening management of valuable data non-threatening management of valuable data

assets.assets.– The goal is to be:The goal is to be:

» TransparentTransparent» SupportiveSupportive» Collaborative.Collaborative.


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Formalization of Data StewardshipFormalization of Data StewardshipCore PrinciplesCore Principles

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• You Have DataYou Have DataYou Have You Have Positive Possibilities Positive Possibilities / Outcomes/ Outcomes

– Improved Decision MakingImproved Decision Making– Improved Customer ValueImproved Customer Value– Improved OperationsImproved Operations

• What impact does Data Governance have on these possibilities / outcomes?What impact does Data Governance have on these possibilities / outcomes?

Formalization of Data StewardshipFormalization of Data StewardshipObjectivesObjectives

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• You Have DataYou Have DataYou Have You Have Negative Possibilities Negative Possibilities / Outcome/ Outcome

– Risk Associated with Regulatory & ComplianceRisk Associated with Regulatory & Compliance– Risk Associated with Security & PrivacyRisk Associated with Security & Privacy– Risk Associated with Classification & Handling Risk Associated with Classification & Handling – Risk Associated with Malicious IntentRisk Associated with Malicious Intent– Risk Associated with Not Knowing the RulesRisk Associated with Not Knowing the Rules

• What impact does Data Governance have on these possibilities / outcomes?What impact does Data Governance have on these possibilities / outcomes?

Formalization of Data StewardshipFormalization of Data StewardshipObjectivesObjectives

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• Data Governance Early Orders of BusinessData Governance Early Orders of Business– OwnershipOwnership of the Data Governance Function of the Data Governance Function– Data Governance Data Governance Roles and Responsibilities Roles and Responsibilities

• CorporateCorporate• SubsidiariesSubsidiaries• External ResourcesExternal Resources

– Data Governance Data Governance Program Manager RoleProgram Manager Role– Data Data Owner vs Data Steward / CustodianOwner vs Data Steward / Custodian Roles Roles

Formalization of Data StewardshipFormalization of Data StewardshipEarly StepsEarly Steps

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Formalization of Data StewardshipFormalization of Data StewardshipWhat It Means to “Govern”What It Means to “Govern”

• [to] [to] gov·ern gov·ern [data][data]

v.v. gov·erned, gov·ern·ing, gov·erns gov·erned, gov·ern·ing, gov·erns – To make and administer the public policy and affairs To make and administer the public policy and affairs – To exercise sovereign authorityTo exercise sovereign authority– To control the speed or magnitude To control the speed or magnitude – To regulateTo regulate – To control the actions or behavior To control the actions or behavior – To keep under controlTo keep under control; ; to restrain to restrain – To exercise a deciding or determining influence To exercise a deciding or determining influence – To exercise political authority To exercise political authority – To have or exercise a determining influenceTo have or exercise a determining influence

FreeDictionary.comFreeDictionary.com

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• Impact of Formal Data Governance – Positive OutlookImpact of Formal Data Governance – Positive Outlook– People understand their relationship to data and the impact they have.People understand their relationship to data and the impact they have.

– People understand the rules associated with definition, production & usage of data.People understand the rules associated with definition, production & usage of data.

– People held formally accountable for their actions with data.People held formally accountable for their actions with data.

– People know when they need to be involved in data-related processes.People know when they need to be involved in data-related processes.

– People are communicated with depending on their relationship to data.People are communicated with depending on their relationship to data.

– People’s behavior associated with their relationship to the data is governed.People’s behavior associated with their relationship to the data is governed.

Formalization of Data StewardshipFormalization of Data StewardshipWhat It Means to “Govern” DataWhat It Means to “Govern” Data

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• Getting the Business to Speak Up. Who is “the Business”? Getting the Business to Speak Up. Who is “the Business”? – Anybody that Defines, Produces and Uses DataAnybody that Defines, Produces and Uses Data– Anybody Who Must Support Data Governance in Order for it to be SuccessfulAnybody Who Must Support Data Governance in Order for it to be Successful– Anybody Who is Supported by or Supports These People ↑Anybody Who is Supported by or Supports These People ↑– Anybody that Sees Room for Improvement Associated with DataAnybody that Sees Room for Improvement Associated with Data– Anybody Who is Feeling the Pain of Not Having the Data they NeedAnybody Who is Feeling the Pain of Not Having the Data they Need– Anybody …Anybody …

– Anybody …Anybody …– Anybody …Anybody …

Formalization of Data StewardshipFormalization of Data StewardshipWhat It Means to “Govern Data”What It Means to “Govern Data”

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• Questions to Get the Business to Describe Where to Expect Value:Questions to Get the Business to Describe Where to Expect Value:

1.1. What can’t you do that you think you should be able to do with the data?What can’t you do that you think you should be able to do with the data?

2.2. What would you want to do if you had the data to support it?What would you want to do if you had the data to support it?

3.3. What data would you like to see to help you do your job better?What data would you like to see to help you do your job better?

4.4. How could your daily routine or interaction with the data be made better?How could your daily routine or interaction with the data be made better?

5.5. What do you spend time on where that time could be reduced?What do you spend time on where that time could be reduced?


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6.6. What data do you use most often to achieve your objectives and describe what it What data do you use most often to achieve your objectives and describe what it takes to get and use that data?takes to get and use that data?

7.7. What is the primary source used by your area to obtain the data? Who do go to What is the primary source used by your area to obtain the data? Who do go to get information about this source data?get information about this source data?

8.8. What processes do you follow that consume the data?What processes do you follow that consume the data?

9.9. Do these processes have data challenges? If so, what are they?Do these processes have data challenges? If so, what are they?

10.10. What is the product or customer impact? How has this been tracked or measured?What is the product or customer impact? How has this been tracked or measured?


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11.11. Is there risk associated with the data – brand, compliance, legal, etc. ?Is there risk associated with the data – brand, compliance, legal, etc. ?

12.12. What is the operational impact (e.g. money, FTEs, manual work-around, etc.) of What is the operational impact (e.g. money, FTEs, manual work-around, etc.) of the challenges? Have you tracked or quantified these impacts? the challenges? Have you tracked or quantified these impacts?

13.13. What other impacts should be noted?What other impacts should be noted?

14.14. Have you identified potential solutions? If so, what is the status of these Have you identified potential solutions? If so, what is the status of these solutions – Scoped, Funded, Planned, In-Flight, etc? solutions – Scoped, Funded, Planned, In-Flight, etc?

15.15. What data / information is on your “wish list” that would better enable your area What data / information is on your “wish list” that would better enable your area to deliver on our Core Competencies? to deliver on our Core Competencies?


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• What We What We ShouldShould Tell Management About Data Governance Tell Management About Data Governance– We ARE already governing data (but we are doing it informally). We ARE already governing data (but we are doing it informally).

– We CAN formalize how we govern data by putting structure around what we are We CAN formalize how we govern data by putting structure around what we are presently doing.presently doing.

– We CAN Improve.We CAN Improve.

– We DO NOT Have to Spend A Lot of Money.We DO NOT Have to Spend A Lot of Money.

– We NEED structure.We NEED structure.

Formalization of Data StewardshipFormalization of Data StewardshipMessages for ManagementMessages for Management

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• What We What We Should Not Should Not Tell Management About Data GovernanceTell Management About Data Governance– Do NOT Sell Data Governance as being A HUGE CHALLENGE.Do NOT Sell Data Governance as being A HUGE CHALLENGE.

– Emphasize that Data Governance is NOT A TECHNICAL SOLUTION.Emphasize that Data Governance is NOT A TECHNICAL SOLUTION.

– Emphasize again that PEOPLE BEHAVIOR IS GOVERNED, Not Data.Emphasize again that PEOPLE BEHAVIOR IS GOVERNED, Not Data.

– Emphasize that Data Governance is an EVOLUTION, NOT REVOLUTION.Emphasize that Data Governance is an EVOLUTION, NOT REVOLUTION.

Formalization of Data StewardshipFormalization of Data StewardshipMessages for ManagementMessages for Management

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• What is meant by Non-Invasive Data Governance?:What is meant by Non-Invasive Data Governance?:

With Data Governance in General:With Data Governance in General:

– Many organizations view Data Governance as being over-and-above normal work Many organizations view Data Governance as being over-and-above normal work efforts and threatening to the existing work culture of the organization.efforts and threatening to the existing work culture of the organization.

It does not have to be that way.It does not have to be that way.

– Many organizations have a difficult time getting people to adopt Data Many organizations have a difficult time getting people to adopt Data Governance best practices because of a common belief that Data Governance is Governance best practices because of a common belief that Data Governance is about command-and-control. about command-and-control.


– While I firmly state that Data Governance is “the execution and enforcement of While I firmly state that Data Governance is “the execution and enforcement of authority over the management of data”, nowhere in that definition does it say authority over the management of data”, nowhere in that definition does it say that Data Governance has to be invasive or threatening to the work, people and that Data Governance has to be invasive or threatening to the work, people and culture of the organization.culture of the organization.


Formalization of Data StewardshipFormalization of Data StewardshipHow Can Governance Be Non-Invasive?How Can Governance Be Non-Invasive?

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With Non-Invasive Data Governance:With Non-Invasive Data Governance:

– Data steward responsibilities are identified and recognized, formalized and Data steward responsibilities are identified and recognized, formalized and engaged according to their existing responsibility rather than being assigned or engaged according to their existing responsibility rather than being assigned or handed to people as more work. handed to people as more work.

– The governance of data is applied to existing policies, standard operating The governance of data is applied to existing policies, standard operating procedures, practices, and methodologies … rather than being introduced or procedures, practices, and methodologies … rather than being introduced or emphasized as new processes or methods. emphasized as new processes or methods.

– The governance of data augments and supports all data integration, risk The governance of data augments and supports all data integration, risk management, business intelligence and master data management activities management, business intelligence and master data management activities rather than imposing inconsistent rigor to these initiatives. rather than imposing inconsistent rigor to these initiatives.


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With Non-Invasive Data Governance:With Non-Invasive Data Governance:

– Specific attention is paid to assuring senior management’s understanding of a Specific attention is paid to assuring senior management’s understanding of a practical and non-threatening yet effective approach to governing data that will practical and non-threatening yet effective approach to governing data that will be taken to mediate ownership and promote stewarding of data as a cross-be taken to mediate ownership and promote stewarding of data as a cross-organization asset, rather than the traditional method of “you will do this”. organization asset, rather than the traditional method of “you will do this”.

– Best practices and key concepts of the non-threatening approach are Best practices and key concepts of the non-threatening approach are communicated effectively, compared to existing practices to identify and leverage communicated effectively, compared to existing practices to identify and leverage strengths and enable the ability to address opportunities to improve. strengths and enable the ability to address opportunities to improve.


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• Concepts of Non-Invasive Data GovernanceConcepts of Non-Invasive Data Governance– Do NotDo Not give employees new job titles and recognize that the majority of their give employees new job titles and recognize that the majority of their

present work will not change.present work will not change.

– Data Stewards are typically Data Stewards are typically NotNot hired. Data Stewards hired. Data Stewards AreAre more often deployed / more often deployed / re-deployed, identified & engaged according to their present responsibilities.re-deployed, identified & engaged according to their present responsibilities.

– A Data Steward is typically A Data Steward is typically NotNot a position. Becoming a Data Steward a position. Becoming a Data Steward IsIs a formal a formal association or accountability for the management of a subset of enterprise data.association or accountability for the management of a subset of enterprise data.

– The Data Stewardship process will The Data Stewardship process will NotNot create new tasks or time commitments but create new tasks or time commitments but instead will ensure that the appropriate Data Stewards are identified, engaged in instead will ensure that the appropriate Data Stewards are identified, engaged in each data related task.each data related task.

Formalization of Data StewardshipFormalization of Data StewardshipKey ConceptsKey Concepts

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• Concepts of Non-Invasive Data GovernanceConcepts of Non-Invasive Data Governance– Data Stewards Data Stewards Will NotWill Not be given additional work over and above their present be given additional work over and above their present

responsibilities. responsibilities.

– Present responsibilities related to data management Present responsibilities related to data management WillWill be formalized & recorded be formalized & recorded to ensure consistent and complete involvement of the appropriate data stewards.to ensure consistent and complete involvement of the appropriate data stewards.

– The time commitment of each Data Steward will depend on the number of projects The time commitment of each Data Steward will depend on the number of projects and data issues which impact their area of expertise.and data issues which impact their area of expertise.

– Data Stewards will be provided the knowledge, tools, forums and processes to Data Stewards will be provided the knowledge, tools, forums and processes to become more effective and more efficient data managers.become more effective and more efficient data managers.

Formalization of Data StewardshipFormalization of Data StewardshipKey ConceptsKey Concepts

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• Criteria for Identifying Best PracticeCriteria for Identifying Best Practice– Is the Statement Is the Statement PracticalPractical, , Do-ableDo-able and will it and will it Add ValueAdd Value??

The answer should be “Yes” or the best practice statement should not be considered.The answer should be “Yes” or the best practice statement should not be considered.– Is the Program Is the Program At Risk At Risk if the practice is not achieved?if the practice is not achieved?

The answer should be “Yes” or the best practice statement should not be considered.The answer should be “Yes” or the best practice statement should not be considered.

Formalization of Data StewardshipFormalization of Data StewardshipBest PracticeBest Practice

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• Sample Best Practice from a Sample Best Practice from a Financial InstitutionFinancial Institution::– There is a There is a High Level of Senior Management Support and UnderstandingHigh Level of Senior Management Support and Understanding of the of the

activities of the Data Governance Team, the roles defined in the Data Governance activities of the Data Governance Team, the roles defined in the Data Governance Operating Model, and specific examples of where Data Governance will add Operating Model, and specific examples of where Data Governance will add value.value.


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• Sample Best Practice from a Sample Best Practice from a Health Care CompanyHealth Care Company::– Staff are committedStaff are committed to the definition, development, execution and sustainability to the definition, development, execution and sustainability

of the Data Governance Program on a continual basis. of the Data Governance Program on a continual basis.


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• Sample Best Practice from Sample Best Practice from Higher EducationHigher Education::– Data Governance Principles are Data Governance Principles are applied consistently and continuouslyapplied consistently and continuously to data to data

that is defined, produced and used for Enterprise Reporting. that is defined, produced and used for Enterprise Reporting.


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Formalization of Data StewardshipFormalization of Data StewardshipRoles & ResponsibilitiesRoles & Responsibilities

• Approaches to Data Governance of Roles & ResponsibilitiesApproaches to Data Governance of Roles & Responsibilities– Non-Invasive ApproachNon-Invasive Approach

• Identifying people into roles rather thanIdentifying people into roles rather than assigning people to roles.assigning people to roles.

• Leveraging existing responsibilityLeveraging existing responsibility

– Command and Control ApproachCommand and Control Approach• Assigning people into rolesAssigning people into roles• Giving people new responsibilitiesGiving people new responsibilities

– 2’ x 4’ Approach2’ x 4’ Approach• Data Governance is “Not Optional”Data Governance is “Not Optional”• People will have to make timePeople will have to make time

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• Non-Invasive Rules for Becoming a Data StewardNon-Invasive Rules for Becoming a Data Steward

1.1. A Data Steward can be absolutely anybody.A Data Steward can be absolutely anybody.

2.2. Being a Data Steward describes a relationship to data and is not a position.Being a Data Steward describes a relationship to data and is not a position.

3.3. A Data Steward is not hired to be a Data Steward.A Data Steward is not hired to be a Data Steward.

4.4. A Data Steward does not need to have the title of “Data Steward”.A Data Steward does not need to have the title of “Data Steward”.


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• Non-Invasive Rules for Becoming a Data StewardNon-Invasive Rules for Becoming a Data Steward

5.5. A Data Steward does not have to be told how to do their job.A Data Steward does not have to be told how to do their job.

6.6. Public or Industry Data Steward Certification is a load of bunk.Public or Industry Data Steward Certification is a load of bunk.

7.7. There is more than one Data Steward for each type of Data.There is more than one Data Steward for each type of Data.

8.8. Data Steward training should be focused on “Formalizing Accountability”.Data Steward training should be focused on “Formalizing Accountability”.


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Formalization of Data StewardshipFormalization of Data StewardshipApplying GovernanceApplying Governance

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• Focused Business & Governance ActivitiesFocused Business & Governance Activities1.1. Identify the Data that you will govern for this initiative.Identify the Data that you will govern for this initiative.2.2. Identify the Data Domains, Subject Areas, Functions, … Identify the Data Domains, Subject Areas, Functions, … for that datafor that data3.3. Identify Sources / Occurrences / System of Record … Identify Sources / Occurrences / System of Record … for that datafor that data4.4. Complete Common Data Matrix Complete Common Data Matrix … for that data… for that data5.5. Identify / Recognize Data Domain Stewards Identify / Recognize Data Domain Stewards … for that data… for that data


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• Focused Business & Governance ActivitiesFocused Business & Governance Activities6.6. Identify / Recognize Operational Data Stewards Identify / Recognize Operational Data Stewards … for that data… for that data7.7. Record Governance Issues Associated Record Governance Issues Associated … with that data… with that data8.8. Prioritize Governance Issues Prioritize Governance Issues … for that data… for that data9.9. Complete Governance Accountability / Activity Matrix Complete Governance Accountability / Activity Matrix … for that data… for that data10.10. Address Governance Issues Address Governance Issues … for that data… for that data


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• Program ActivitiesProgram Activities– Best PracticesBest Practices– Governance PolicyGovernance Policy– Operating ModelOperating Model– Action PlanAction Plan

• ProactiveProactive• ReactiveReactive

– Communications PlanCommunications Plan– Gain Executive and Strategic … Gain Executive and Strategic …

• SupportSupport• SponsorshipSponsorship• UnderstandingUnderstanding• EngagementEngagement


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Formalization of Data StewardshipFormalization of Data StewardshipBill of “Rights”Bill of “Rights”

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• What You Can Do Right Now?What You Can Do Right Now?– Give Somebody the Responsibility for Data GovernanceGive Somebody the Responsibility for Data Governance– Engage Someone That Has Done This BeforeEngage Someone That Has Done This Before– Start with a Start with a Best Practice Critical Analysis Best Practice Critical Analysis & & Actionable PlanActionable Plan– Start & Stay with Start & Stay with Formalization of Data Stewardship Framework of RolesFormalization of Data Stewardship Framework of Roles– Emphasize the Need for Emphasize the Need for Communications and AwarenessCommunications and Awareness– Do Not Follow a Technical or Technology SolutionDo Not Follow a Technical or Technology Solution– Do Not Follow an Invasive or Command & Control SolutionDo Not Follow an Invasive or Command & Control Solution– Do Not “Throw Money” at the Discipline / Not NecessaryDo Not “Throw Money” at the Discipline / Not Necessary– Take an Iterative & Incremental ApproachTake an Iterative & Incremental Approach

Formalization of Data StewardshipFormalization of Data StewardshipNext StepsNext Steps

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• Robert S. SeinerRobert S. SeinerKIK Consulting & Educational Services – KIKconsulting.comKIK Consulting & Educational Services – KIKconsulting.comThe Data Administration Newsletter – TDAN.comThe Data Administration Newsletter – TDAN.comPost Office Box 112571, Upper St. Clair, Pennsylvania 15241Post Office Box 112571, Upper St. Clair, Pennsylvania 15241412.220.9643, 412.220.9644 (Fax)412.220.9643, 412.220.9644 (Fax)[email protected]@[email protected]@tdan.com

Formalization of Data StewardshipFormalization of Data StewardshipContact InformationContact Information

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1 Copyright © 2015 Robert S. Seiner – KIK Consulting & Educational Services / TDAN.com Copyright © 2015 Robert S. Seiner – KIK Consulting & Educational