Compliance
Writing Good Data Governance Policy in Wealth Management

Recent legislation, such as the EU's GDPR regulations and MiFID II rules mean that wealth managers' data procedures must be sharpened up. This article examines the terrain.
Nicola Askham is a UK expert on how organisations and individuals should handle data goverance, coaching entities such as banks in this vital yet often neglected discipline. She recently wrote on why data governance is often the missing link for wealth managers.
Here, she explains why wealth managers should go about writing effective data governance policy. This news service is pleased to share these views. For readers who want to join into the debate, email the editor at tom.burroughes@wealthbriefing.com
It won’t surprise you to learn that I sometimes find myself
writing a data governance policy for my clients. This is really a
bespoke job.
As with all things relating to data governance, I don't think
that there is such a thing as a standard approach, and there
certainly is not one for a data governance policy. If there is no
such thing as a standard data governance framework, why would you
think that a policy written for another organisation would work
for you?
This is particularly true of wealth managers as they differ so
much in terms of models, markets, propositions and target client
segments.
Key initial questions to answer
For a policy to be really useful and fulfil its purpose of
helping you embed robust data governance successfully it needs to
be written with your organisation in mind.
It should address the following questions:
-- What is the scope of your data governance
programme?
-- What will your organisation do to manage its data
better?
-- What roles and responsibilities need to be
assigned to carry out these steps?
-- What kind of processes are you going to implement
as a result of having a data governance programme?
The answers to these questions will not be the same for all
companies and I can honestly say that every organisation I have
ever worked with has been unique in its approach to data
governance. I admit that sometimes the differences are subtle,
but for a policy to be valuable, these subtleties really do need
to be addressed.
Writing policy from scratch
There is no shame to be just starting out in data governance, but
start all firms must in a regulatory environment where it is an
increasing focus. I recommend the following approach:
First, assemble key senior stakeholders and discover which
principles they want included in the policy. What are the
high-level things that you want to achieve by having a data
governance framework and policy in place?
This could be things like “all data has a data owner”, or it
could be describing which data will have data quality standards
and monitoring in place, or which data will have definitions in
your data glossary (in simple terms, a guide to the data an
organisation has, where it is and what’s done with it).
For some clients, this list of principles has been as long as
twelve and for others as short as six.
A collaborative approach to what should be included in the data
governance policy helps get principles agreed. With the
principles agreed, drafting your policy in accordance is fairly
straightforward.
One thing you cannot do without, however, is the engagement of
senior stakeholders. If this framework is to be successful, it
needs to have buy-in from everyone. So, you need to take all
input at this stage very seriously.
Differences of opinion will doubtlessly need to be worked
through, but these discussions will provide invaluable insights
for when you are designing a more detailed data governance
framework for your organisation.
I suspect that many wealth managers will have been codifying
their culture and business practices around data governance for
the first time off the back of GDPR, MiFID II and other
regulatory changes.
What I hope they see quickly is that good data governance can
bring big benefits to the business, not least in managers knowing
exactly what they have in terms of data – which is of course one
of their most valuable assets.