Non-Invasive Framework for Data Governance Implementation – Part 1: Levels and Components

ART01x - image_editIntroduction

The following paper is the first of a two-part brief description of the Seiner Non-Invasive Framework for Data Governance Program implementation. Part Two can be found here. The framework was developed and is implemented by Robert S. Seiner of KIK Consulting & Educational Services and The Data Administration Newsletter ( Seiner is an experienced data governance specialist and the developer and practitioner of the Non-Invasive Data Governance™ approach. Seiner is also the author of the book (10/2014) named after the NIDG approach.

The framework is broken into the primary components of delivering a successful program and the levels of the organization to which the components of data governance must be applied. The detail of what is required to deliver a successful program occur where each level (row) is addressed for each component (column) in the framework.

An image of the Seiner Non-Invasive Framework for Data Governance Implementation is shown below:


The Levels of the framework are mostly people and authority based. Many organizations use similar definitions when it comes to defining how they operate. The levels defined in this framework should look familiar to you if you are acquainted with the Non-Invasive Data Governance™ Operating Model of Roles & Responsibilities described in my book, presentations, and webinars.

The Framework Levels are defined as:

  • Executive – Senior Leadership Team
  • Strategic – Business & Technology Management
  • Tactical – Subject Matter Expertise
  • Operational – Daily Job Function
  • Support – Functional Management

The Components of the framework are the core moving parts of governance in action for most organizations. The components focus on clear roles and responsibilities including how to resolve issues, engage, and communicate with each of the defined levels. The second to last component focuses on the definition of success and value for the data governance program, and the association of how and who to measure for these metrics.

The Framework Components are defined as:

  • Roles (Authority) – Formal Responsibility
  • Processes – Application and Enforcement
  • Communications – Education, Training and Awareness
  • Metrics – Measurements and Key Performance Indicators (KPIs)
  • Tools – Artifacts Purchased & Developed

The Framework Levels


The Executive level of an organization typically consists of people at the top level. This includes Presidents, Chairs, Senior Vice Presidents, and CXO level positions (meaning CEOs, COOs, CIOs, CDOs, CROs, CMOs, etc.). The Executive Level of an organization often has regular or scheduled meetings as the Steering Committee for the enterprise.

In NIDG – Data Governance is added as a line item on the agenda of regular Executive level meetings. The Steering Committee is composed of business and technology leadership for Data Governance and all other Enterprise level initiatives.


The Strategic level of an organization typically consists of people that report directly to and are delegated by the Executive level to oversee and direct specific initiatives. This can include Senior Vice Presidents, Vice Presidents, and the people that are recognized as being second-in-command or as representing their part of the organization in the initiative. The Strategic level is accountable to the Executive level for the success of the initiative.

In NIDG – The Strategic level is often labeled as the Data Governance Council. The Council’s responsibility is to make certain the Data Governance program is successful. The Council is very knowledgeable in the policies and procedures of Data Governance and acts as the ultimate decision maker for resolving issues that cannot be resolved at a lower level of the organization.


The Tactical level of an organization typically consists of people that are subject matter experts, facilitators, and potentially decision makers for specific domains of data and information. The Tactical level is delegated or recognized by the Strategic level as people that must be included in and drive decisions that are made regarding data in their domain. The Tactical level can be defined by policy, through appointment, or through a natural selection process (the “go-to person”).

In NIDG – The Tactical level is often labeled as Data Domain Stewards or Enterprise Data Stewards for a specific subject matter of data. Domain Stewards are recognized for their expertise in their subject matter across the Enterprise. This role is the most critical role of a NIDG program and can be the most logical or difficult to fill. Domain Stewards can have the authority to make Enterprise decisions for their subject matter or they may escalate the decision to an information Strate­gic level.

The Tactical level may also include Information Owners – although the author of this framework suggests to avoid the use of the term “owner” when possible. The Information Owner label can be appropriate in situations where rules must be followed in a specific part of the organization.


The Operational level of an organization typically consists of every person in the organization that has a relationship to data and that is (or will be) held formally accountable for that relationship. The relationships include the definition, production, and/or use of data and information. If an individual does any or all of these activities as part of their job, it is a requirement that these people follow policy, best practices and standards for that relationship. The key focus of Data Governance is to assure that select high quality data is reused, and handled appropriately.

In NIDG – The Operational level can include everybody in the organization. These people are known as the true stewards of the data – or people that are or will be formally accountable for how they define, produce, and use data. These people do not require a title of Data Steward. From the operational on up through the hierarchy, people must be held formally countable for their actions associated with the data. In NIDG, specific and thorough attention is paid to governance awareness at all levels whether that awareness focuses on quality, protection, or management of the data.


The Support level of an organization typically includes the people responsible for the Data Governance program, the supporting knowledge of Information Technology (IT), Project Management (PMO), Regulatory and Compliance groups, Information Security, Legal and Audit, Working Groups; any group that has a vested interest in the “execution and enforcement of authority over the management of data.”

In NIDG – The Support level varies with the program design in each organization. Leadership of the Data Governance program is the critical level of support, and the support and involvement of IT and the PMOs act as stalwart contributors to the most successful programs.

The Framework Components

Roles (Authority)

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 push-back when the effort is over-and-above existing responsibilities. Identification into roles encounters less push-back as people 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.


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 process.


Communication is an important component 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 program definition and delivery. Communications must be thorough and measureable. 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.


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 require benchmarks of present state and 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, quantifying education, awareness and certification of handling rules and incidents that are formally attended.

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.


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 specific metadata needs of their Data Governance program.

The Seiner Non-Invasive Framework for Data Governance Implementation follow-up paper details the breakdown of components by level, providing the full consideration that must be given to each intersection of the two levels. This framework’s sole purpose is to provide details of primary considerations for implementing a Non-Invasive Data Governance™ program.

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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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