Non-Invasive Framework for Data Governance Implementation: Details, Part 2

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In the first part of this paper I detailed the levels and components of a Non-Invasive framework for successful data governance program implementation. In the second part, I provide the full considerations that must be given to each intersection of the rows (levels) and columns (components). This framework’s sole purpose is to detail primary considerations when implementing a Non-Invasive Data Governance™ program.

The following graphic represents a high-level view of the framework. Please refer to part one to learn more details about the levels and components.

The graphic for the framework is shown below:

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In part two, I have detailed the framework and described each of the necessary components level by level. For some organizations, it may make sense to order your details by component within each level if attempting to describe the framework to a certain set of people.

The following tables provide considerations for each of the components by level:

Roles (Authority)

As stated in Part One, the first foundational component of a successful Data Governance program is the definition of roles and responsibilities. The manner in which roles are defined is a predictor of the effort required to govern the data. Assignment into roles often presents pushback when the effort is over-and-above existing responsibilities. Identification into roles encounters less pushback as people already see themselves in the roles that they have been slotted. Recognition of people into roles is a direct manner of acknowledgement of the part each person plays in the program.

In NIDG, Roles are typically represented through a NIDG Operating Model of Roles & Responsibilities. The familiar pyramid diagram is represented in the first column of the NIDG Framework. The Operating Model and accompanying artifacts provided as part of the approach include a detailed description of formalized responsibilities, escalation and decision paths, how roles are formally engaged in processes, and communications that are shared with each level.

Executive Level:Steering Committee (Delegate) It is the role of the Steering Committee to sponsor, approve, understand, and champion the enterprise strategic data plan and policy at the Executive level. The Committee must communicate with lines of business the expectations and requirements for data governance and identify and prioritize data initiatives. The Committee delegates responsibility for strategic decision making to the Council.
Strategic Level:Council (Decision) It is the role of the Data Governance Council to become educated in what data governance means, how it can and will work for the organization, and what it means to embrace and activate the data stewards. The Council approves things like data policy, methods, priorities, and tools, and promotes governance into their areas by actively engaging in improved data practices. The Council makes data decisions at a strategic level in a timely manner given the appropriate knowledge to make that decision, and meets regularly to stay informed of program activities.
Tactical Level:Domain Stewards Owners (Subject) It is the role of the Domain Steward (often referred to as Owner or Subject Matter Expert – SME) to focus on the quality, value, and protection of data that falls under a specific domain (subject area) for the enterprise. These people are identified by position and are involved/facilitators in cross-business resolution of data issues pertaining to their domain. The Domain Steward may or not be the authority (decision-maker), depending on their position in the organization. The Domain Stewards is responsible for escalating well-documented issues to the strategic level, documenting data classification rules, compliance rules, and business rules for data in their domain. The Domain Steward often participates in tactical work groups for finite periods of time to address specific issues and projects related to their domain.
Operational Level:Data Stewards (Daily) It is the role of the Data Stewards to demonstrate accountability for their relationship to the data they define, produce, and use in their daily job. The Data Stewards are educated and often certified as knowing the rules associated with data definition, production, and usage.
Support Level:DG Lead Work Groups Partners (Function) It is the role of the Support areas of the organization, including Data Governance Leadership and the associated team, and partners across the organization including Information Technology, Information Security, Audit, Legal, Risk Management and Project Management (to name several), to support the activities of the Data Governance program by being a part of working teams and participating in activities appropriate for their support areas.


The second foundational component of a successful program is the way the Roles are applied to processes. The notion of the “Data Governance process” misrepresents the fact that processes are a primary component of Data Governance success. There is not a single process that is governed; rather, there are a series of processes to which Data Governance will be applied.

In NIDG, Data Governance programs typically provide repeatable processes that reflect the appropriate level of formal accountability throughout the process. Data Governance focuses on getting the “right” person involved in the “right” step of the process to deliver the “right” result, regardless of the process focus—issue resolution, protection, quality, project-focused—Data Governance becomes the application of formal governance to processes.

Executive Level:Endorse Processes The Executive level must be knowledgeable about the processes that are being governed and the way that they are being governed. The Executive level should understand the impact of governing the process, the resources required, and have supported / reasonable expectations for the value this will bring to the enterprise. Once the Executive level has this understanding, it is their responsibility to endorse, support, and sponsor the governed processes.
Strategic Level:Resolution Processes The Strategic level takes the Executive endorsement of governed processes to an actionable level. The Strategic level identifies and oversees the Data Governance Team’s activities and key processes and players at the Tactical level. The Council resolves process issues brought to them for Strategic decision-making, and meets on a regular basis to review Data Governance process activities.
Tactical Level:Domain Processes The Tactical level is closely engaged to manage data domains (subject areas) by utilizing enterprise Subject Matter Experts. The Tactical level initiates and facilitates resolution of cross-business area processes and data issues regarding their area of expertise. The Tactical level directs and coordinates the Operational level activities of Stewards in their part of the organization, and escalates issues to the Strategic level as necessary.
Operational Level:Daily Processes The Operational level is engaged daily in governed processes defined at the Tactical level and enforced at the Strategic level. The Operational level is educated and certified in following the processes and rules associated with defining, producing, and using data. The Operational level reports changes in efficiency and effectiveness to the Tactical level to drive continual process improvement.
Support Level:Enforce Processes The Support level enforces the governed processes. The Support level includes the Data Governance Team, Information Security, Risk & Compliance, Project Management, Legal / Audit, and others that assure that processes are enforced through education and technology.


The third foundational component, Communications, is a very important piece of a successful Data Governance program. Raising the data awareness of every person that defines, produces, and uses data is critical to achieving program success. Education must focus on policies, handling rules, best practices, standards, processes, and role-based governance activities.

In NIDG, Communications play a role in every aspect of a program’s definition and delivery. Communications must be thorough and measurable. Communications must focus on formalizing accountability for the processes mentioned above: issue resolution, protection, quality, project-focused, or any other application of authority to how data is managed.

The Communications Plan must mirror the Roles component described above. Communications must include orientation, on-boarding, and ongoing subjects focused toward the specific audience utilizing available communication instruments.

Executive Level:Support Sponsor Understand Best practice dictates that the Executive levels support, sponsor, and, most importantly, understand how data governance works in the organization. To achieve this, the communications plan plays an important role. Governance information must be shared effectively so as to resonate and become adopted at the Executive level. The Executive level will only support and sponsor Data Governance if they understand the who, what, why, where, and when concerning how the NIDG program will proceed.
Strategic Level:Meetings Status The Strategic level receives regular (scheduled) communications on governed process status. The Strategic level approves detailed governance policy and practice through regular review of program communications and status. The Strategic level pushes communications into their business areas and demonstrates thorough support of governed activities.
Tactical Level:Subject Process Governance communications focus on subject areas of data and the rules and processes associated with defining, producing, and using data in the Tactical domains. The Tactical level is involved in developing education, awareness, and governance materials focused on their subject area of data and related processes across the organization.
Operational Level:Orientation On Boarding Ongoing The Operational level receives communications focused on how they will be held formally accountable for governing data. The Operational level follows the approved rules and governed processes while monitoring and reporting governance results. The Operational level is oriented to data governance, brought onboard at the appropriate time, and receives ongoing communications associated with governing data.
Support Level:Plan Develop Deliver The Support level, including all governance-style parts of the organization (mentioned previously), communicate appropriate formal behavior advocated by their function. The Support level coordinates with the Data Governance Team to provide thorough, current, and regular communications about governing data.


The fourth foundational component of a NIDG program is Metrics. Data Governance programs must be able to measure their impact on the organization. This is the responsibility of the Support role, often called the Data Governance Lead and Team. The impact and value may be financially quantifiable—but this may not always be the case. Measuring efficiency and effectiveness improvements requires benchmarks of present state, as well as the governed activity of measuring and reporting results.

In NIDG, Organizations measure improvements in governance through collecting and reporting the number of issues recorded and addressed. While also quantifying the value of issue resolution, organizations quantify education, awareness, and certification of handling rules, and incidents that are formally attended to.

Data Governance metrics and measurements must be auditable and demonstrable to management and authorities when requested. Organizations typically count the reusability and understandability of data definition, the ability and speed to access the “right” data at the “right” time, the production of high quality data, and the proper usage and handling of data.

Executive Level:Metrics Approval Act The Executive level reviews and approves the way governance is implemented and how value is measured across the organization. The Executive level receives results from the Strategic, Tactical, and Support levels, and acts to address improvement of governance capabilities.
Strategic Level:Metric Acceptance The Strategic level works with the Tactical and Support levels to define and deliver acceptable processes to measure Data Governance. The Strategic level promotes active benchmarking and delivery of measurable metrics and business value to the Executive level.
Tactical Level:Domain Metrics The Tactical level defines how governance is measured in relationship to domain level quality requirements and the need to protect data in that domain. The Tactical level delivers metrics associated with domain focused data definition, production, and usage across the organization.
Operational Level:Daily Measurements The Operational level is measured in terms of efficiency and effectiveness in defining, producing, and using data throughout their daily processes. The Operational level follows process and procedure to define, collect, report, and analyze the value of governance to the operations, individuals, and teams in the organization.
Support Level:Collect Report Metrics It is the responsibility of each Support level area to define, produce, and report effective metrics and measurements to demonstrate the governance value they are providing to the organization. Value will include improvement in business operations, reduction of risk, and the ability to protect data; as well as the improvements in the value received from the data and improved analytical capabilities.


The final foundational component of a NIDG program is Tools. Tools of Data Governance enable the program to deliver value to the organization. Organizations use tools they develop internally as well as tools that they’ve purchased to fill specific needs of their programs. The tools that are developed or purchased are based on practicality, ease-of-use, and the specific goals of the Data Governance program.

In NIDG, Tools are used to formalize accountability for the management of data and improve the knowledge of the data, rules, and processes required to govern data. Tools are used to record and make available metadata in order to improve the understanding and quality of data across the Enterprise.

The Data Governance Tool market is growing as the definition of Data Governance expands to address authority enforcement over big data, smart data, metadata, and all data used for analytics. Prior to investing in new technologies, organizations should clearly state their requirements, consider leveraging existing tools, and develop tools internally to address the specific metadata needs of their Data Governance program.

Executive Level:Policy Directive The Executive level is responsible for issuing the directive to govern data across the organization. This directive takes the form of policy and written statements outlining the Executive level’s support, sponsorship, and understanding of the core and guiding principles of data governance and the approach that will be followed by the organization. A dashboard for delivery of governance results to the Executive level is valuable for program sustenance.
Strategic Level:Best Practice Guidelines The Strategic level is responsible for accepting governance Best Practice, and the assessment and critical analysis of how the organization compares to the best practices and guidelines. The Strategic level accepts the action plan and roadmap for bringing the organization into alignment with proposed data governance best practices and supports the Tactical, Operational, and Support levels of the organization to achieve a best practice state.
Tactical Level:Standards Requirements Workflow The tools of the Tactical level include approved data quality standards and requirements for improving the governance of data per domain across the organization. The Tactical level is responsible for developing and promoting data requirements, standards, and governed workflows to the Strategic level for approval, and enforcement by the Support level of the program.
Operational Level:Glossary Dictionary Metadata The Operational level uses metadata tools to improve their ability to define, produce, and use data as part of their daily job. The Operational level provides business definitions of data used to build business glossaries, data dictionaries, and other metadata resources. The Operational level assists in mapping data meaning and legacy across disparate information systems and data stores.
Support Level:KIK Artifacts(Common Data Matrix Activity) The Support level delivers tools associated with their business function, including software focused on improving the Information Technology, Information Security, Risk and Compliance, Audit, Legal, and Project Management functions. The Data Governance Team uses customize-able templates and models to improve the performance of their program and maximize value of data governance.

The Seiner Non-Invasive Framework for Data Governance Implementation Part One detailed the foundational components and organizational levels that must be considered to be successful with your NIDG program. Part Two provides the detailed components by level.

There are many approaches to data governance. If you are not implementing data governance in a non-invasive manner, I hope the framework includes ideas that can further your data governance discipline and provide additional successes to complement your program.

This paper provides a Non-Invasive Framework for Data Governance Implementation and considerations for implementing a NIDG program. Please contact the author or for more information about how to use this framework.

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

Copyright © 2016 – Robert S. Seiner – KIK Consulting & Educational Services

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Robert S. Seiner

Robert S. Seiner

Robert (Bob) S. Seiner is the President and Principal of KIK Consulting & Educational Services and the Publisher Emeritus of The Data Administration Newsletter. Seiner is a thought-leader in the fields of data governance and metadata management. KIK (which stands for “knowledge is king”) offers consulting, mentoring and educational services focused on Non-Invasive Data Governance, data stewardship, data management and metadata management solutions. Seiner is the author of the industry’s top selling book on data governance – Non-Invasive Data Governance: The Path of Least Resistance and Greatest Success (Technics Publications 2014) and the followup book - Non-Invasive Data Governance Strikes Again: Gaining Experience and Perspective (Technics 2023), and has hosted the popular monthly webinar series on data governance called Real-World Data Governance (w Dataversity) since 2012. Seiner holds the position of Adjunct Faculty and Instructor for the Carnegie Mellon University Heinz College Chief Data Officer Executive Education program.

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