Data policies and procedures
Learning outcome statements
The learning outcome statements relevant for this section are:
- define data governance
- demonstrate a general understanding of data governance frameworks, including COSO’s Internal Control—Integrated framework
Definition of data governance
Data governance involves establishing policies, procedures, and responsibilities to ensure data is accurate, consistent, and compliant with regulatory requirements.
Data governance has four primary objectives:
The COSO’s internal control-integrated framework
Organizations rely on structured data governance frameworks to ensure proper data oversight. Management typically selects which frameworks to adopt based on the organization’s regulatory requirements, industry standards, and business needs. These frameworks provide structured guidelines that help maintain compliance, security, and operational efficiency while ensuring that data governance aligns with the company’s strategic objectives.
One of the most widely recognized frameworks is COSO’s internal control—integrated framework, which provides a structured approach for risk management, internal controls, and data integrity.
Objectives
The COSO internal control—integrated framework categorizes internal control objectives into three main areas:
- Operations: Ensuring the effectiveness and efficiency of business operations, including safeguarding assets and optimizing processes to support organizational goals.
- Reporting: Supporting the reliability, timeliness, and transparency of financial and non-financial reporting to facilitate informed decision-making.
- Compliance: Ensuring adherence to applicable laws, regulations, and internal policies to mitigate legal and financial risks.
These objectives provide a foundation for organizations to design and implement internal controls that enhance data governance, risk management, and overall business integrity.
Key components
The COSO framework is built upon five interrelated components, often referred to as the five pillars, which are further broken down into 17 guiding principles. These pillars serve as the foundation for implementing effective internal controls, including those applied to data governance.
Pillar 1: Control environment
This pillar establishes the tone at the top, promoting ethical behavior, accountability, and clear lines of authority. For example, a company with a well-defined control environment enforces a code of conduct, provides regular training on governance policies, and maintains a whistleblower policy so employees can report governance violations.
Pillar 2: Risk assessment
Identifies and evaluates risks that could prevent the organization from achieving its objectives, including risks to data security. For example, a company might classify data by sensitivity level, use predictive analytics to anticipate data security threats, and establish a formal risk response plan with contingency measures for potential cybersecurity threats.
Pillar 3: Control activities
Focuses on the policies and procedures that help ensure management’s directives are carried out, including controls that safeguard data. For example, a financial institution may enforce segregation of duties, run automated data validation checks, and restrict data modifications based on employee roles, so only authorized personnel can update critical records.
Pillar 4: Information and communication
Ensures that relevant information is identified, captured, and communicated so people can carry out their internal control responsibilities. For example, a company conducts regular training sessions so employees at every level understand their data governance responsibilities.
Pillar 5: Monitoring activities
Involves ongoing and periodic evaluations to confirm that internal controls are functioning as intended. For example, a company may conduct internal audits and track key performance indicators (KPIs) to monitor data quality over time.
The data life cycle, records retention requirements, and controls against security breaches — including technology controls such as firewalls and access controls — are covered in later chapters, including life cycle of data and controls against security breaches.
