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A regional financial services company providing institutional, commercial and mortgage banking services faced significant challenges in managing and governing its vast data ecosystem. The initial project created a custom data governance framework to address several problems: leadership’s low confidence in the data, unreliable and untrustworthy reports, unclear ownership, process redundancies, and a lack of insights and predictions for the future.
The implementation of the data governance framework quickly focused on the criticality of implementing the record retention workstream, as the risk of legal and regulatory exposure was concerning to leadership.
Our data governance experts led the design of the enterprise data governance strategy, the build of a robust and customized operational data governance framework, and creation of the implementation roadmap.
To shape the enterprise data governance strategy, we met with the leadership team to understand the company’s challenges, goals and potential risks. We then defined the scope of the program, established high-level roles and responsibilities, documented the value proposition, and aligned priorities for the short, medium and long term.
The operational data governance framework designed how the program would be executed for governance, data quality, data security, data integrity and controls, data archiving and retention, and risk management workstreams. Our data governance team customized complex data governance concepts into actionable steps, established key milestones, and customized deliverable templates to ensure the activities were fit for purpose.
The implementation of the operational data governance framework would occur over multiple years and focus on the bank’s highest priority applications. Timelines, key dependencies and the critical path was included in the implementation roadmap.
Subsequently, the team implemented the record retention program, involving identification of the bank’s records, mapping of the records to over 500 relevant laws and regulations, and coordination with legal counsel to create the record retention schedule.
After finalizing the record retention schedule, we organized the bank’s 125-plus applications into manageable phases, or tranches, following a risk-based approach to assess the record deletion capabilities, estimate the deletion effort and perform the deletion process. Rigorous testing was performed to validate the capability of the applications to delete the data as established by the retention schedule. As issues were identified, we worked with the client and third-party providers to find solutions and with the client to determine feasible workarounds.
Addressing software limitations required close collaboration with the client and third-party providers to resolve issues, request additional functionality and document risks. By breaking the record retention implementation workstream into tranches, the team was able to systematically work through various challenges on time and within budget.
The implementation of the data governance framework and record retention schedule yielded transformative results for our client. The safeguarding, retention and destruction of customer information is especially critical in banking, one of the most highly regulated verticals. Violations for insufficient policies and procedures are as common as regulatory citations for failure to follow written guidelines or provide evidence of compliance.
By implementing rigorous data governance and record retention policies and processes, the client realized several positive outcomes: full compliance with laws and regulations, the ability to meet audit and litigation requests, lower data retention costs, and the avoidance of unnecessary risks from keeping excess records.