Eschew Obfuscation, Espouse Elucidation – How To Enhance Data Quality Governance With Third-Party Providers
Eschew obfuscation, espouse elucidation appeared in print as early as 1959, when it was used as a section heading in a NASA document. Contemporary use of the expression may be attributed to English teachers and professors as an ironic or humorous comment when lecturing about proper writing techniques. A literal translation of the phrase equates to “Avoid ambiguity, adopt clarity” or in the urban parlance; K.I.S.s aka Keep. It. Simple (stupid)!
In principle, this is the only way to achieve sound data quality governance in financial services, especially where outsourced service providers are involved. Even though reputable third-party providers have data governance frameworks and performance metrics in place, it is important to recognise inherent bias and that data quality governance is not often a core capability.
Data quality must be independently and routinely monitored and validated. If access to the data can be obtained, an independent audit can often uncover moderate to widespread error for which regulatory breach and costly remediation is a legitimate risk.
Since the introduction of CPG235, responsible entities with in-sourced arrangements have predominantly seized the initiative in developing and implementing data governance frameworks. These organisations typically utilise data quality software to execute detective controls that promote both offensive and defensive data strategies. This results in both significant reductions of time and effort across remediation programs and access to truly ‘good data’, that is leveraged to govern, innovate, engage, retain and grow.
The turbulence of the Royal Commission and now COVID-19 has increased regulatory scrutiny and added to ongoing legislative demands. The need for independent oversight of material services on which your organisation relies and importantly the underlying data has never been greater.
The existence and appropriateness of a data governance control environment (even in the case where data governance itself is outsourced), is the duty of responsible persons to validate. No longer may it be assumed, taken on faith or weaknesses plausibly denied.
How to enhance data quality governance with third-party providers
For organisations with outsourced arrangements, with known or unknown data governance deficiencies, rapid uplift may be realised by:
Undertaking an independent evaluation of the outsourced data control framework (at the third-party).
Introduce or enhance provisions in contractual arrangements, to bind providers to minimum standards, principals and penalties.
Use a data quality management software tool that provides visibility of data quality issues, as close to source as possible and on near real-time basis.
Implement a reporting dashboard that summarises data quality state on a given frequency, complete with weighted scores and benchmark analysis (segregated by operational domain).
Embed an evidence-based data health discussion within service reviews and agree to identified data event ‘actions to prevent recurrence’.
The financial services industry is unified on the critical nature of data governance and we all know the true value of data is directly linked to its quality. Responsible persons need to take a ‘keep it simple’ approach to position themselves to effectively and impartially evaluate data governance narratives from third-party providers; confusing and convoluted or clear and concise.
Regards
Mike
Mike Wilcox - National Manager, Strategic Partnerships
If your organisation needs assistance with data quality governance at third-party providers, QMV can help.
QMV’s extensive work in data quality management, governance and remediation led to the development of Investigate. Investigate is a purpose-built data quality software platform that amalgamates disparate sets of data into a single vantage point. Data quality across an organisation or supply chain may be viewed and managed on a repeatable and auditable basis.
Please reach out to QMV for further information on p +61 3 9620 0707 or submit an online form.
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