BCBS 239 and Solvency II have driven the Data Governance Agenda for banks and investment firms. New drivers are on the horizon.
The regulatory assessment process has started and banks have the IMMEDIATE task of finalising and submitting their plan for “Full Compliance” within the next few days. That plan has to be submitted by Internal Audit to the Regulators.
The plan must define the scope of “Full Compliance”, describe the activities involved and explain how the plan integrates with other business, cultural, governance, change and regulatory programmes across the bank.
At the EDMworks Data Practitioner Network on 2nd June we review the current state of the regulatory assessments and discuss with leading GSIBs how banks are creating the “Plan for Full Compliance”. We also look to the future to explore the next major drivers for data governance in the European region.
Three seemingly unconnected pieces of legislation will fundamentally change the data management landscape over the next three years. They all have different causes, but their combined effect will be to ENFORCE accountability for data, REINFORCE governance, UNDERPIN data architecture and MANDATE data quality management:
The General Data Protection Regulation (GDPR) changes the rules and accountabilities for security around personal data and transforms penalties for data breaches from “cost of doing business” to “bankrupting the business”.
The Network and Information Security Directive (NISD) focuses on identification, registration and accountability for critical networks or systems. The scope covers financial, telecoms, utilities and other types of business. It is the European Union’s response to cyber terrorism.
On 7th March 2016, the Senior Manager and Certification Regime (SMCR) was implemented as a self-regulating framework for senior management accountabilities across the finance sector. This provides the legislative structure for the PRA/FCA to demand individual accountability for and oversight of critical business functions. The NISD and GDPR will use this framework to ensure personal accountability for data assets across the organisation.
Over the last five years, huge investments have been made on improving data quality, underlying infrastructure and governance oversight. Most GSIBs claim o have achieved "Material Compliance" and now have the task of submitting their "Plan for Full Compliance" in June 2016.
This session reviews the current status of BCBS 239 "Material Compliance", the approach that regulators are taking in assessing compliance and looking at the key components and activities that have to be part of "Plan for Full Compliance".
Colin Gibson, Global Architecture Director, Willis Towers Watson
Tom Dalglish, Senior Integration & Data Manager, HSBC
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