Data Leaders members can access the full two-part summary from this discussion via the Data Leaders Hub.

Data Leaders brought together experienced practitioners to advise a client, who is navigating a crucial phase of its digital and data management transformation, on best practice approaches to the successful implementation of the comprehensive Consumer Data Management and Compliance (CDMC) framework. The discussion focused particularly on how to effectively engage with business units and operating entities in a decentralised organisation to boost adoption and minimise resistance to central governance policies.

What is the CDMC Framework?

The CDMC is a framework designed to guide organisations in the responsible collection, storage, processing, and sharing of consumer data. The primary goal of CDMC is to ensure that companies manage consumer data in a way that complies with legal and regulatory requirements, such as GDPR in Europe, CCPA in California, and other privacy laws globally. It encompasses aspects of data privacy, security, governance, and ethics, focusing on safeguarding consumer information against unauthorised access, breaches, and misuse.

Peer Insights

Data Leaders discussions are vendor-free, giving CDOs a confidential space in which to candidly share their experience. During this discussion, there was plenty of acknowledgement of the challenges in implementing CDMC and the patience and commitment required to build respectful relationships that ultimately open the doors to successful collaborations and compliance.

Here are the key pieces of practical advice offered by peers on how they have been able to advance the adoption of the framework across their organisations:

1. Adopt a Business-Led Approach

While it can be tempting to lead a governance implementation from a technology or process perspective, CDOs repeatedly warn against this approach, citing that it leads to more resistance and misalignment with business priorities. Instead they emphasise that data governance should prioritise business objectives by empowering business owners to set the agenda rather than IT departments. This approach ensures that strategies are driven by real business outcomes and specific purposes, aligning the governance structure with the actual needs and priorities of the business, thereby increasing effectiveness and relevance.

2. Create a Central Marketplace for Data Products

Central marketplaces are a popular and effective strategy to democratising not just data but its associated governance. A central marketplace where business owners can independently develop, manage, and share their data products – with support from the Data Office – facilitates better control and visibility over data assets, enabling more effective data usage and decision-making within the company.

3. Adopt a Federated Governance Approach

Adopting a federated model of governance that combines overarching central policies with the flexibility of localised implementation allows central Data Officers to establish standard guidelines that can be adapted to fit the unique needs and contexts of various business units. This is key for promoting consistency while accommodating diversity, such as local laws and practices, within a large organisation.

4. Position Governance as a Fast Track to Value

One of the biggest challenges cited by CDOs when rolling out frameworks like CDMC is how to make the topic of governance engaging and appetising. One suggestion is to shift the narrative by avoiding positioning governance as a restrictive force to instead posing it as a facilitator of business value. By portraying governance as providing ‘guardrails’ that guide business units along a ‘happy path‘ to compliance, its perception can be changed to make it more about enabling success than enforcing rules.

5. Bake Governance into Delivery Processes

Automation and process integration are key to side-stepping resistance to compliance, so CDOs strongly advocate for the integration of CDMC mechanisms. By making compliant pathways the easiest and most straightforward to follow, organisations can demonstrate the tangible benefits of governance, thereby accelerating desired business outcomes.

6. Define Data Domains

Clearly defined data domains, such as client or consumer data, establish a common understanding of data management objectives across various jurisdictions. This ensures that each entity within the organisation has clear ownership and responsibility while simultaneously facilitating the adaptation of central governance policies to local requirements and cultural practices.

7. Collaborate Closely with Local Stakeholders

Close collaboration with local stakeholders, especially local Chief Security Officers (CSOs) and Data Protection Authorities (DPAs), are key to building mutual understanding, trust and respect when it comes to the implementation and application of the CDMC frawework at a local level. Look to explain central policies and to support their adaptation. Conduct Data Protection Impact Assessments (DPIAs) to ensure that governance policies are not only compliant but also respectful and reflective of local knowledge and legal requirements. This approach helps tailor governance measures to specific local needs, fostering greater acceptance and effectiveness.

8. Facilitate the Sharing of Best Practices

Encourage the sharing of best practices and the establishment of competency centres across various operational entities. By valuing the contributions of different units and providing a platform for learning and collaboration, CDOs can minimise resistance to new governance policies and their implementation can be made more palatable and effective.

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