The “Non-Invasive Data Governance”™ Operating Model

A few years ago, as part of a series of articles titled “The Stewardship Approach to Data Governance,” I defined a framework of roles and responsibilities associated with implementing a “Non-Invasive Data Governance”™ program. Several of the chapters of that series dissected the diagram you see below and addressed specifically the different layers and sidebars of the pyramid diagram.

In the past articles I have labeled the pyramid as a Framework of Roles & Responsibilities. Given recent scenarios at a handful of clients, I have changed my terminology. I now refer to the framework as the “Non-Invasive Data Governance”™ Operating Model. I use the term “Operating Model” because the roles and responsibilities of a “Non-Invasive Data Governance”™ program play such a crucial operational role in the success or failure of this type of endeavor – from best practices, to acceptability, to long-term sustainability.

Several times over the years I have been asked to consolidate all of the roles and responsibilities into a single article and I have always hesitated … until now. In this article I am providing (variations on) all of the bulleted information from the earlier articles and slide presentations incorporating the past several years of experience in using the model.

For further commentary on the different components of the Non-Invasive Data Governance Operating Model, please refer back to the earlier articles that explain the Strategic Level, the Tactical Level 1, the Tactical Level 2, the Operational Level and the Support Level. If you have any questions after reading this article, or the past article, please drop me a line and we can talk about it.


The rest of this article will define (in one place) each of the layers and components of the KIK Consulting “Non-Invasive Data Governance”™ Operating Model; starting with the sidebars on the left and finishing with the layers from the bottom to the top of the pyramid:

The Support Level

The responsibilities of the Data Governance Program Team are:

  • Overseeing enterprise data governance program development.
  • Architecting the solution and framework.
  • Administering the program, including facilitating the data governance council meetings.
  • Providing the agenda for the data governance council meetings to the approved by council owner pre-meeting.
  • Facilitating data governance organization, tactical and operational stewards, the data governance council involvement.
  • Developing and delivering data governance program educational, awareness and mentoring materials.
  • Providing quality assurance – oversight, monitor, report results to governance council.
  • Establishing, maintaining, and periodically reviewing and recommending changes to data. governance policies, standards, guidelines, and procedures.
  • Assisting in defining data quality metrics for periodic release.
  • Supporting data quality issue analysis and remediation for “strategic” data.
  • Conducting audits to ensure that policies, procedures and metrics are in place for maintaining/improving the program.

The responsibilities of Information Technology (Data SMEs and System SMEs) are:

  • Focusing on consistent protection/classification of data by data classification (confidential, public, internal use, …).
  • Technical handling of data to meet data classification requirements.
  • Securing IT infrastructure on behalf of the business units that own or have responsibility for data.
  • Assuring that sensitive data, regardless of format, is protected at all times by only using approved equipment, networks, and other controls.
  • Championing the integration of data governance within the standard project methodology.
  • Ensuring that standard project methodology is followed and that policies, procedures and metrics are in place for maintaining/improving data quality and the creation, capture and maintenance of metadata.
  • Ensuring that all “strategic” data is modeled, named, and defined consistently.
  • Ensuring that projects source and utilize data as much as is feasible from the designated system of record.
  • Providing technical support for ensuring data quality.
  • Providing technical support for data governance and data cleansing efforts where required.
  • Ensuring that metadata critical to data governance is included in the metadata resource and is accessible.

Operational Level

The responsibilities of the Operational Data Stewards are:

  • Defining the data that will be used by the organization, how that data will be used, and how that data will be managed – data definers.
  • Producing, creating, updating, deleting, retiring, archiving the data that will be managed – data producers.
  • Using data to perform their job and processes and the Integrity of data usage.
  • Creating/reviewing/approving data definitions.
  • Integrity and quality of data definition.
  • Producing, creating, updating, deleting, retiring, and archiving the data that will be managed.
  • Integrity and quality of the data created or updated in their department or process.
  • Identifying and classifying data access levels.
  • Identifying and documenting regulatory and legal/risk issues including data retention requirements.
  • Supporting/sharing knowledge w/other stewards.
  • Communicating new and changed business requirements to individuals who may be impacted.
  • Communicating concerns, issues and problems with data to the individuals that can influence change.

Tactical Level

The responsibilities of the Data Domain Stewards (one per data domain – subject area of data) are:

  • Focusing on the quality of data in a domain (subject area in most cases) for the “enterprise.”
  • Identified by position (or person) as part of a single business unit or functional area.
  • When acting in role of data domain steward, affiliation to business unit becomes secondary.
  • Involved/facilitator in cross business unit resolution of data definition, production and usage issues.
  • May or not be the authority (decision maker). Depends on position in the organization.
  • Escalating well-documented issues to the strategic level with or without recommendation.
  • Documenting data classification rules, compliance rules, business rules for data in their domain (may delegate this).
  • Making certain the rules are communicated to all stakeholders of data in that domain (may delegate).
  • Participating in tactical groups (with other domain stewards, steward coordinators, and operational stewards) for finite periods of time to address specific issues and projects related to their domain and business unit.

The responsibilities of the Data Steward Coordinators (one per unit, division or functional area) are:

  • Acting as the point communications person for distributing rules and regulations per domain of data to the operational stewards in their business unit (and making certain that the operational data stewards understand the rules and risks).
  • Acting as the point communications person for their business unit to document and communicate issues pertaining to specific domains of data to the proper data domain steward.
  • Acting as the point person in the common data matrix (or data steward repository) regular change control process.
  • Identifying the operational stewards of data per domain for their business unit. This typically requires research and inventory time for the data steward coordinator.
  • Working alongside the data domain stewards and operational data stewards on specific tactical data steward teams that are set up for the duration of issue resolution or project focused task.
  • The data steward coordinator typically has no decision making authority but plays a pivotal role in data governance and data stewardship success.
  • In the common data matrix, they should fill in the operational data stewards per domain for the domains in which their business unit are stakeholders. This may require the coordinator to research exactly how and what data is being defined, produced and used in their business unit.

Strategic Level

The responsibilities of the Data Governance Council are:

  • Becoming educated in what data governance means, how it can and will work for the organization and what it means to embrace data governance and activate your enterprise data stewards.
  • Approving things that need to be approved – i.e., data policy, data role framework, methods, priorities, tools, etc.
  • Pushing data governance into their areas by actively promoting improved data governance practices.
  • Making decisions at a strategic level in a timely manner given the appropriate knowledge to make that decision.
  • Meeting regularly (or send alternate), read minutes to stay informed of data governance program activities.
  • Identifying and approving of pivotal data governance roles including cross-enterprise domain stewards and coordinators.
  • Advising the data governance council owner in applying data governance to risk management, compliance, business unit-specific governance interests.

Executive Level

The responsibilities of the Data Steering Committee (or other named steering committee) are:

  • Sponsoring, approving, championing the enterprise strategic plan and policy.
  • Communicating with lines of business the expectations and requirements for data governance.
  • Identifying and prioritizing data quality initiatives.

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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 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 has hosted the popular monthly webinar series on data governance called Real-World Data Governance (w Dataversity) since 2012. Seiner recently accepted the position of an Adjunct Instructor for the Carnegie Mellon University Heinz College CDataO post-graduate program. KIK Consulting is celebrating its 20th year in business while has been actively published for close to 25 years.

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