Developing a Data Governance Policy: A Playbook for CIOs

Introduction

As many industries have more-widely adopted standardized practices around data management and governance, these practices are becoming solidified by various governing bodies and officially managed by legal regulators. As such, B2B organizations must establish robust data governance policies to protect sensitive information, ensure compliance, and optimize data management processes. This whitepaper serves as a comprehensive playbook for CIOs to build and implement an effective data governance strategy. We’ll guide you through three critical phases, providing detailed context, additional steps, and best practices to achieve a holistic data governance framework.

Phase 1: Creating Written Policies

Before any technical work can begin, the first step to developing a data governance program is to create the written framework for how data is managed. This is the process of stepping back and considering all the organization’s needs, getting them onto paper, and understanding how they all work together.

Typical considerations at this stage are:

• Compliance regulations that your business needs to adhere to.
• Your customers, the compliance regulations that they adhere to, and will those affect your data governance program.
• Your technology stack and solutions in-use currently
• The gaps in your technology stack and solutions and future tools/solutions
• Key stakeholders and the data/files that they need access to and their ability to grant access to data/files to internal and external stakeholders.
• The data/files that need to be managed under this program, how is it organized now and how it needs to be organized under this program.
• The cybersecurity policies necessary to incorporate into this program.
• The technical requirements needed to implement this program.

Once you’ve developed an understanding of these key areas and how they function together you’ve created a roadmap for success in your data governance policy.

Understand Compliance Standards

The foundation of any data governance policy begins with a thorough understanding of the compliance standards applicable to your industry. Identify and review relevant regulations and policies, including national and international regulations such as:

• General Data Protection Regulation (GDPR): Governs data protection and privacy in the European Union.
• California Consumer Privacy Act (CCPA): Provides data privacy rights to California residents.
• Health Insurance Portability and Accountability Act (HIPAA): Regulates the protection of health information in the United States.
• Industry-Specific Standards: Depending on your sector, you may need to comply with specific regulations such as:
• Financial Industry Regulatory Authority (FINRA): For financial services.
• Controlled Unclassified Information (CUI): For federal contractors.
• ISO 20000: Sets standards for IT service management.
• ISO 27001: Specifies criteria for an information security management system
• ISO 9001: Specifies criteria for a quality management system.
• NIST: 800-171
• NIST: 800-53
• Cybersecurity Maturity Model Certification (CMMC): Ensures cybersecurity practices for defense contractors.
• Capability Maturity Model Integration (CMMI): Provides best practices for process improvement.
• System and Organization Controls (SOC 2 Type 2): Focuses on controls related to security, availability, processing integrity, confidentiality, and privacy.
• Payment Card Industry Data Security Standard (PCI DSS): Establishes security standards for handling payment card information.
• Family Educational Rights and Privacy Act (FERPA): Protects the privacy of student education records.
• Gramm-Leach-Bliley Act (GLBA): Requires financial institutions to explain how they share and protect private customer information.

Conduct a Compliance Gap Analysis

Perform a compliance gap analysis to identify areas where your current data management practices fall short of regulatory requirements. This involves mapping out existing data flows, assessing data collection and processing activities, and evaluating compliance risks.

Evaluate Your Existing Tech Stack and Solutions

Before developing a comprehensive data governance policy, it is crucial to evaluate your current technology stack and solutions. This involves identifying all data assets, software applications, hardware infrastructure, and existing data management processes within your organization. Start by conducting a thorough inventory that details the types of data being collected, stored, and processed, as well as the systems and tools used to handle this data. Understanding your existing tech stack will help pinpoint potential vulnerabilities, compliance gaps, and inefficiencies that may need to be addressed. Additionally, this evaluation enables you to leverage current technologies and align them with your data governance objectives, ensuring that your policy is built on a foundation of existing resources and infrastructure.

Anticipate Future Needs in Your Tech Stack

As you design your data governance policy, it is equally important to anticipate future technology needs and trends. The landscape of data management and compliance is continually evolving, driven by advancements in technology and changes in regulatory requirements. Forecasting future needs involves assessing potential growth areas, emerging technologies, and upcoming regulations that could impact your data governance strategy. This forward-thinking approach ensures that your policy remains agile and scalable, capable of accommodating new data sources, integrating advanced data analytics tools, and complying with future regulations. By having a clear understanding of future needs, you can make informed decisions about investing in technologies and processes that will enhance your organization’s data governance capabilities over time.

Identify Key Stakeholders and Define Access Levels

Understanding who the key stakeholders are in a data governance policy is pivotal to its success. Stakeholders include anyone who interacts with data within the organization, such as data owners, custodians, analysts, and end-users. These individuals or groups have distinct roles and responsibilities, and their involvement in the policy is essential to ensure comprehensive data management. Mapping out key stakeholders helps in establishing accountability, clarifying ownership, and streamlining communication across various departments.

Defining different access levels and controls is equally important for maintaining data security and integrity. Not all stakeholders require the same level of access to data, and granting unrestricted access can lead to potential data breaches or misuse. Establishing a tiered access control system ensures that stakeholders have appropriate permissions based on their roles and responsibilities. This includes setting up role-based access controls (RBAC), implementing measures like data encryption, and conducting regular audits to monitor access and usage. By clearly delineating access levels and controls, you can protect sensitive information while allowing stakeholders to efficiently perform their duties, thereby balancing security with usability.

Understand Current File Organization and Develop an Organizational Plan

Before moving forward with a data governance plan, it is essential to have a comprehensive understanding of all existing files and their current organization within your systems. This step involves conducting a detailed audit of your file storage architecture, including both electronic and physical documents. By thoroughly documenting the current state of your files, you can identify any redundancies, inconsistencies, or gaps in your data management practices.

An organized file system is critical for efficient data retrieval, compliance, and security. Therefore, the audit should encompass all aspects of file management, such as naming conventions, folder structures, access permissions, and storage locations. During this process, it can be helpful to categorize files based on their type, sensitivity, and usage frequency to gain insights into the most effective ways to manage them.

After gaining a clear picture of your current file organization, it is necessary to develop a strategic plan for how you want files to be organized moving forward. This plan should address the deficiencies uncovered during the audit and align with your overall data governance objectives. Consider implementing standardized naming conventions, streamlined folder structures, and robust classification schemes to enhance data consistency and accessibility. Additionally, outline procedures for regular file maintenance, such as archiving outdated documents, purging obsolete files, and updating metadata.

By understanding the current state of file organization and having a plan in place for future organization, you can create a strong foundation for your data governance policy. This proactive approach ensures that your data management practices are both scalable and sustainable, ultimately enabling better data quality, compliance, and security.

Importance of Understanding Cybersecurity Protocols and Their Implementation

Incorporating robust cybersecurity protocols into your data governance policy is paramount to safeguarding sensitive information, ensuring regulatory compliance, and maintaining stakeholder trust. Cybersecurity protocols encompass a wide range of practices and technologies aimed at protecting data from unauthorized access, breaches, and other cyber threats. Understanding these protocols and their application within your organization is critical in mitigating vulnerabilities and preventing data breaches.

Start by evaluating your current cybersecurity measures, including firewalls, intrusion detection systems, antivirus software, encryption techniques, and access control mechanisms. Conduct regular security audits to identify potential weaknesses and to ensure that existing protocols are up-to-date and effective against evolving cyber threats. Additionally, staying informed about the latest cybersecurity trends and emerging threats is crucial for maintaining a proactive security posture.

Implementing cybersecurity protocols within your data governance policy involves integrating these measures into everyday data management practices. This includes enforcing strong password policies, conducting employee training on cybersecurity awareness, and establishing incident response plans. Role-based access control (RBAC) should be rigorously applied to limit access to sensitive data based on the principle of least privilege, ensuring that only authorized personnel can access critical information.

Regularly updating and testing your cybersecurity protocols is equally important. This involves patch management, vulnerability assessments, and penetration testing to identify and rectify security flaws. By embedding robust cybersecurity measures into your data governance policy, you create a resilient framework that not only protects data but also enhances the overall integrity and reliability of your data management practices. This proactive approach instills confidence among stakeholders and ensures that your organization is well-equipped to tackle current and future cybersecurity challenges.

By the end of Phase 1, you should be able to…

Define Policies and Owners

At the end of Phase 1, all written policies should be created and clearly defined. Each policy must have designated owners responsible for ensuring adherence. Establishing clear ownership is crucial for accountability and effective policy enforcement. There should be three types of data owners:

• Data Owners: Senior executives or managers responsible for the overall data strategy, policy creation, and ensures data is maintained and sets access requirements to align with business objectives.

• Data Stewards: Mid-level managers who oversee data quality, enforce policies, and facilitate communication between data owners and custodians.
• Data Custodians: IT personnel responsible for managing data storage, implementing security measures, and maintaining data integrity. Custodians ensure that data is protected as accordance to the standards set by data owners.

Develop a RACI matrix (Responsible, Accountable, Consulted, Informed) to clearly define the roles and responsibilities of each data owner.

Phase 2: Implementing Policies

Configure Policies in Microsoft Purview

With written policies in hand, the next step is to configure them within Microsoft Purview. Microsoft Purview offers a range of features that help implement compliance policies effectively:

• Data Classification: Automatically classify data across your environment using built-in sensitive information types and customizable labels.

• Policy Management: Create, manage, and deploy data policies from a centralized interface. You can define rules for data access, retention, and handling based on your written policies.
• Data Mapping: Visualize data lineage to understand the flow of information across systems and identify points of risk.

Classify and Label Data

Data classification and labeling are essential for preventing data leaks and unauthorized access. Implement a comprehensive classification framework that includes:

• Data Types: Categorize data based on its type (e.g., personal data, financial data, intellectual property).

• Sensitivity Levels: Assign sensitivity levels (e.g., public, internal, confidential, restricted) based on the potential impact of data exposure.

• Retention Policies: Define retention periods for different data types to ensure compliance with legal and business requirements.

Microsoft Purview’s capabilities in this area include:

• Automatic Labeling: Apply labels automatically based on predefined rules, ensuring consistent classification.

• Manual Labeling: Allow users to manually apply labels to documents and emails, providing flexibility and control.

• Content Explorer: View how data is labeled and classified across your organization, helping to ensure adherence to policies.

Implement Labeling Mechanisms

Tagging and labeling documents add an extra layer of security and control. Labels serve two primary functions:

• Retention: Defines how long data should be kept and when it should be disposed of.

• Sensitivity: Determines who can access, view, or edit the data based on its sensitivity level.

For example, for Controlled Unclassified Information (CUI) used by federal agencies or government contractors, labels can restrict actions such as downloading or accessing files from non-company devices.

Configure Data Lifecycle Management

Implement policies around data lifecycle management to ensure data is properly managed from creation to disposal. Key steps include:

• Data Retention and Archiving: Define policies for retaining and archiving data based on legal, regulatory, and business requirements.

• Data Disposal: Establish procedures for securely disposing of data that is no longer needed.

• Data Encryption: Implement encryption mechanisms for data at rest and in transit to protect against unauthorized access.

• Data Access Controls: Define and enforce access controls to limit who can view, edit, or share data.

Microsoft Purview enhances data lifecycle management through features like:

• Retention Labels: Automatically apply retention labels to content, ensuring data is retained according to policy.

• Disposition Reviews: Set up workflows for reviewing and approving data disposal, adding an extra layer of oversight.
• Audit Logs: Maintain detailed logs of data access and handling activities, supporting compliance and forensic investigations.

Insider Risk Management

Mitigate insider risks by restricting specific activities like printing or downloading sensitive files. Implement monitoring and logging mechanisms to track user actions and generate audit trails. Key considerations include:

• Activity Restrictions: Restrict or monitor high-risk activities such as copying data to external devices or accessing data from remote locations.

• User Behavior Analytics: Use advanced analytics to detect unusual behavior patterns that may indicate insider threats.
• Incident Response: Develop incident response plans to address potential data breaches or policy violations promptly.

Microsoft Purview provides tools for insider risk management, including:

• Insider Risk Management: Identify and mitigate risks from insiders using machine learning algorithms and behavioral analytics.

• Alerts and Reports: Generate alerts for suspicious activities and create reports for compliance and management review.
• Case Management: Manage and investigate potential insider risk cases with built-in case management tools.

By the end of Phase 2, you should be able to…

Develop Technical Assessments

Utilize Microsoft Purview to conduct technical assessments. These assessments provide a comprehensive view of your data environment and help identify potential compliance gaps. Key steps include:

• Data Discovery and Classification: Use Microsoft Purview’s data discovery tools to locate and classify data across your organization.

• Risk Assessment: Evaluate the risk associated with different types of data and determine appropriate mitigation measures.
• Documentation: Compile detailed documentation of your data assets, classifications, and risk assessments to support compliance efforts and prepare for potential audits.

Implement Written Policy into Purview

At this stage, your written policy should be fully implemented into Microsoft Purview.

1. Comprehensive Policy Implementation: Successfully configure and implement data governance policies within Microsoft Purview, ensuring all data access, retention, and handling rules are clearly established and enforced.
2. Effective Data Classification and Labeling: Develop and apply a robust classification and labeling framework that categorizes data based on type, sensitivity, and retention requirements, utilizing both automatic and manual labeling processes.
3. Enhanced Data Security through Labeling: Implement labeling mechanisms that define retention periods and control access based on data sensitivity, reinforcing data security.
4. Streamlined Data Lifecycle Management: Establish and enforce data lifecycle management policies that cover data retention, archival, disposal, encryption, and access controls, ensuring data is managed efficiently from creation to disposal.
5. Insider Risk Mitigation: Put in place comprehensive insider risk management strategies, including activity restrictions, user behavior analytics, and incident response plans to detect, monitor, and respond to potential insider threats.
6. Monitoring and Compliance: Utilize Microsoft Purview’s tools such as content explorer, audit logs, insider risk management, alerts, and case management to monitor compliance, generate reports, and handle potential incidents efficiently.

Accomplishing these outcomes will ensure your organization is well-equipped to handle data governance, compliance, and security challenges effectively.

Phase 3: Pre-Deployment Audits and Training

Conduct a Self-Audit

Before rolling out the policies company-wide, conduct a thorough self-audit to prepare for external compliance audits. A self-audit helps identify potential weaknesses in your data governance framework and ensures that all policies and procedures are effectively implemented. Key steps include:

• Internal Review: Conduct an internal review of your data governance policies, processes, and controls.

• Mock Audits: Perform mock audits to simulate external compliance reviews and identify areas for improvement.
• Documentation: Ensure all documentation related to data governance is up-to-date and readily accessible for audit purposes.

Microsoft Purview aids in self-audit preparation with:

• Compliance Manager: Use Compliance Manager to assess your compliance posture, track assessment progress, and generate reports.

• Continuous Monitoring: Continuously monitor compliance status and receive actionable insights to improve your compliance efforts.
• Evidence Collection: Collect and store evidence of compliance activities, making it easier to respond to audit requests.

End-User Training

End-user training is critical for the successful implementation of data governance policies. Conduct comprehensive training sessions in batches based on user tiers to ensure everyone understands their responsibilities and the importance of compliance. Key considerations include:

• Role-Based Training: Tailor training sessions based on users’ roles and responsibilities, focusing on the specific policies and procedures relevant to their functions.

• Regular Updates: Provide regular updates and refresher training to keep users informed about changes in policies and emerging compliance requirements.

• Feedback Mechanisms: Implement feedback mechanisms to gather input from users and continuously improve training programs.

Conclusion

Developing and implementing a data governance policy is a complex but essential task for any B2B organization. By following this playbook, CIOs can ensure that their data governance strategies are robust, compliant, and effectively protect sensitive information. The structured approach outlined in this document provides a solid foundation for building a comprehensive data governance framework that meets regulatory requirements and supports business objectives.

If you’re looking for guidance on developing your data governance policies and procedures, R3 is an experienced managed IT services, managed security services, and compliance as a service provider.

Schedule a free, no obligation, consultation session with a member of our governance, risk and compliance team today.