by John Ladley
We interviewed Chris Deger for this issue. Chris Deger headed the data governance program at Wachovia Bank and managed some pretty impressive accomplishments. Given that full life cycle implementation of data governance is still rare, Chris had our full attention. Although the statements represented in this interview illustrate Wachovia Bank’s data governance efforts, they are strictly the opinion of Chris Deger and do not represent the company itself.
J.L.: Chris, you spoke about data governance at the recent Wilshire Conference this past summer. Do you have a formal governance function at Wachovia?
C.D. Yes, for risk information. We began with credit risk data focused on BASEL II compliance data and intended to move to operational and market risk data next. Ultimately the framework and organization we implemented could be used for all data.
J.L.: How many people are involved in the data governance program at Wachovia?
C.D.: Overall there are approximately 300 participants. We implemented a centralized/decentralized model consisting of a Risk Data Council, Data Governance Office, and a Data Stewardship Community. There is a Risk Data council that reports to the C level executives. It has 13 members and they meet every other month. There are 10 full time employees in the Data Governance Office providing centralized services for the program like cross-organizational issue resolution, coordination, and mentoring. Everyone else is in the decentralized Data Stewardship Community – Lead Data Stewards, Data Stewards and Subject Matter Experts from Business, Technology, Operations, and Risk.
J.L.: Was everyone clear about what data governance meant?
C.D.: That was a big challenge. When I first took over the program we didn’t have a clear and concise definition so I googled it and never found a really useful standard definition. I knew if the program were to be successful we would need a clear definition as a reference for people to understand and use going forward so we drafted Wachovia’s definition.
J.L.: Was the definition readily accepted?
C.D.: People were a little resistant to the scope of the definition with regard to how ambitious we were being but once people understood how broad data governance was, it became the standard.
J.L.: Was there a problem or event that triggered Wachovia’s data governance program or was it an evolutionary process?
C.D.: Both. Wachovia has grown rapidly over the last 10 years or more by merger and acquisition. When you grow that way you have a tremendous amount of data integration that must occur in a very short amount of time. Eventually we reached critical mass around data quality and control. Through an internal data integrity initiative we discovered that data quality was not as good as we needed it to be. So we started to investigate our options to address our challenges of which implementation of a data governance program was a part. That was the evolution. The event was that while we were developing a strategic and tactical approach, Basel II came to the forefront and we interpreted that as an additional driver for data quality and data governance.
J.L.: So data governance was based on a recognized internal need coupled with compliance issues.
C.D.: Yes, and more. We had been through several compliance intitiatives like SOX and AML so the Operating Committee was looking for something with greater value than just compliance. The changes we ultimately proposed seemed radical at the time but represented an opportunity to address long standing challenges and provide for value beyond compliance.
J.L.: Was there a culture change management issue along with the radical change?
C.D.: Yes. The primary focus of the data governance program is to change the culture by establishing data as a corporate asset and driving accountability back into the lines of business to those that understand it best. Any change in an organization has its challenges but one like ours, that is looking to change the culture in the way that we are, must address change management formally. Because Wachovia has grown by merger and acquisition, we have both an organization and extensive processes for facilitating culture change. We tapped into these existing resources right from the start.
J.L.: Did you work with or for corporate compliance?
C.D.: No, the program is based in Risk Management. Wachovia is a member of the IBM Data Governance Council and the council interprets the scope of data governance to include the areas of compliance and information security. At Wachovia we have long standing organizations that address compliance and information security and do an excellent job already so those areas were not included in our scope. We focused on the life cycle of risk data and its quality and control starting with the business processes.
J.L.: Any turf wars?
C.D.: No, we all played pretty well together. One of the things that helped was that the program went through a formal communications planning process. We started early with compliance folks, explained what our scope was and that we didn’t want to take their jobs. We also looked at where we could find synergies between our groups.
J.L.: Were there any other functions you considered or interacted with besides compliance?
C.D.: Some people think data governance is the same as data management, it’s not. In our interpretation data management is the management of infrastructure. We went to great pains to differentiate these roles within the organization. The analogy I like to use is around building a house – the plumber lays the pipes and hooks things together then tests to make sure nothing leaks. But once the water is running through the pipes he doesn’t go out to his truck and get a water test kit and test the quality of the water. It’s not his core competency. Data governance has to be done by those that understand how the data is used in the business processes not by those who are trusted to hold and safeguard it. But, you can’t have successful data governance if you don’t have a partnership between the business, IT, and operations.
The great challenge of any data governance program is to identify and treat data quality and control issues at the root cause. Wachovia, like lots of other companies, is being challenged with long standing data cleansing activities that treat symptoms, are done downstream, and becoming more expensive every day. We wanted to reduce the difficulty and cost of these activities by identifying and resolving quality issues at the source and by creating better quality data through appropriate controls vs. fixing it on the back end. Our operations organization does data cleansing well but it was becoming a huge effort and exponentially more expensive.
J.L: Was there any specific technology that you used within governance?
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C.D.: Given where we were in the maturity of the program, we had to take a two track approach. Our interim strategy was to initially develop homegrown tools to support the services and functions of the program. Then the long term strategy is to leverage the tools currently being implemented for data management in the IT and Operations organizations. One of those tools is a workflow engine and we intend, long term, to leverage that workflow engine to support the Data Governance Office and the distributed Data Stewardship Community.
Another way data governance is being related to technology is that the IT and Operations organizations are currently leveraging our stewardship community to validate and approve any business rules being employed for ETL transformation, reference data, and meta data in the new data warehousing platform.
J.L.: How long did it take you to get your data governance program to a good place?
C.D.: If I count the involvement of vendors it would be 12 months, but from the time I became the Program Manger it was 9 months until we were operational. Most folks don’t believe me when I say that. But we were very aggressive. Also, we weren’t hindered with predetermined constraints or expectations so we just went for it. We started with a Vision Statement that was bold, developed a strong change management and communications plan, developed charters for the major organizational components, developed and ratified Policies and Standards, established formal processes with clear roles and responsibilities, developed formal and informal training, with all the work being based on a clear definition of data governance and the scope of the data we were starting with.
J.L.: That is impressive. Looking back, how would you grade or assess your success?
C.D.: I give the programs an A. Everyone that worked in this program had never done anything like this before. The current result demonstrates their commitment and flexibility.
J.L.: So this has been an effective program? It has benefited the business?
C.D.: Absolutely. There has been a qualitative improvement in data and many other aspects of data governance. Many long standing issues that weren’t addressed before are currently being addressed. We also enabled a level of cross organizational activity that allows for greater levels of transparency between divisions, even though the silos are still there.
J.L.: Any other comments you would like to make?
C.D.: I just want to say that I believe Wachovia has demonstrated that data governance is critical to the”business” success of large corporations. Data governance is both a strategic and tactical discipline that must be established in every organization. It’s mission critical stuff and not optional.
About Christopher Deger
Christopher Deger is a demonstrated leader who enjoys problem solving through working with all levels of an organization. He has been responsible for establishing Risk Data Governance Programs in the Financial Services Sector. In this capacity he has developed (organizationally & functionally) and staffed organizations from the ground up. He has facilitated the development and implementation of processes directed at ensuring compliance with internal and external regulatory practices (i.e. BASEL II, SOX, corporate policy & standards).
Chris holds both Process Management & Project Management (PMP) Certifications. His diverse career and domain experience has afforded him the opportunity to mentor & teach for over 27 years. His military career in Army Special Forces provided him the opportunity to experience high performance teams first hand and to develop the ability to build and manage those kinds of teams.
Chris is currently a Senior Managing Consultant in the Financial Services – Business Risk Management practice at IBM.
ABOUT THE AUTHOR
John Ladley
John Ladley is an internationally known information management practitioner and a popular speaker on information and knowledge management. John is widely published and has several regular columns. Until recently, John was a Director with Navigant Consulting. Prior to Navigant, John founded KI Solutions, and John was Senior Program Director of Data Warehouse strategies and a Research Fellow at Meta Group. Mr. Ladley is an authority on information architectures, business performance measurement architectures, knowledge management, collaborative applications, and information resource management. John is currently President of IMCue Solutions, a new firm focused on data governance and information management.
