Becky Briggs, BSMP, CMQ/OE, CBIP Director/Data Steward ARC May 10, 2011 Data Governance How to Keep...

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Becky Briggs, BSMP, CMQ/OE, CBIP Director/Data Steward ARC May 10, 2011 Data Governance How to Keep Your DG Program Viable for the Long Haul

Transcript of Becky Briggs, BSMP, CMQ/OE, CBIP Director/Data Steward ARC May 10, 2011 Data Governance How to Keep...

Page 1: Becky Briggs, BSMP, CMQ/OE, CBIP Director/Data Steward ARC May 10, 2011 Data Governance How to Keep Your DG Program Viable for the Long Haul.

Becky Briggs, BSMP, CMQ/OE, CBIP

Director/Data Steward ARCMay 10, 2011

Data Governance

How to Keep Your DG Program Viable for the Long Haul

Page 2: Becky Briggs, BSMP, CMQ/OE, CBIP Director/Data Steward ARC May 10, 2011 Data Governance How to Keep Your DG Program Viable for the Long Haul.

© 2011 ARC

ARC (Airlines Reporting Corporation)

ARC is a technology solutions company providing transaction settlement and data information

services.We manage the Global Travel Industry Data

Warehouse$80B travel settlement sales a year

193 Million transactions annuallySettle transactions with ~200 airlines

~2.5 B transactions stored in GDW

ARC PROPRIETARY AND CONFIDENTIAL. This document includes confidential information that is proprietary to Airlines Reporting Corporation (ARC). Disclosure of this document or any information contained herein to third parties is prohibited without the prior written consent of an authorized ARC officer. Obsolete versions of this document should be destroyed in a manner to prevent compromise of the information, e.g., shredding. 2

Page 3: Becky Briggs, BSMP, CMQ/OE, CBIP Director/Data Steward ARC May 10, 2011 Data Governance How to Keep Your DG Program Viable for the Long Haul.

© 2011 ARC

Why Data Governance

Warehousing all US based travel agency sold airline tickets for

60+ months Data sharing implications across

and among travel agencies, airlines, airline alliances,

bankruptcies, mergers, etc. Sensitive data encryption and on-

going managementInternal data management and

securityData is our business and data

quality is our reputationAt risk if data is exposed or lost

EU Safe Harbor/PCI/other Compliance requirements

ARC PROPRIETARY AND CONFIDENTIAL. This document includes confidential information that is proprietary to Airlines Reporting Corporation (ARC). Disclosure of this document or any information contained herein to third parties is prohibited without the prior written consent of an authorized ARC officer. Obsolete versions of this document should be destroyed in a manner to prevent compromise of the information, e.g., shredding. 3

Page 4: Becky Briggs, BSMP, CMQ/OE, CBIP Director/Data Steward ARC May 10, 2011 Data Governance How to Keep Your DG Program Viable for the Long Haul.

© 2011 ARC

What is Data Governance?

Work from the premise that Information is a Strategic Asset - Data is the very Lifeblood of your

Business

“Data governance is the act of managing the organization’s

data assets in a way that promotes business value,

integrity, usability, security, and consistency across the

company”

ARC PROPRIETARY AND CONFIDENTIAL. This document includes confidential information that is proprietary to Airlines Reporting Corporation (ARC). Disclosure of this document or any information contained herein to third parties is prohibited without the prior written consent of an authorized ARC officer. Obsolete versions of this document should be destroyed in a manner to prevent compromise of the information, e.g., shredding. 4

Page 5: Becky Briggs, BSMP, CMQ/OE, CBIP Director/Data Steward ARC May 10, 2011 Data Governance How to Keep Your DG Program Viable for the Long Haul.

© 2011 ARC

High Cost of Point Solutions

“Organizations that choose individual solutions (people,

policies, procedures or technology) for each regulatory challenge they face will spend 10x more on compliance and governance than those that

leverage each implementation for multiple requirements”

Gartner Symposium ITxpo October 2005

ARC PROPRIETARY AND CONFIDENTIAL. This document includes confidential information that is proprietary to Airlines Reporting Corporation (ARC). Disclosure of this document or any information contained herein to third parties is prohibited without the prior written consent of an authorized ARC officer. Obsolete versions of this document should be destroyed in a manner to prevent compromise of the information, e.g., shredding. 5

Page 6: Becky Briggs, BSMP, CMQ/OE, CBIP Director/Data Steward ARC May 10, 2011 Data Governance How to Keep Your DG Program Viable for the Long Haul.

© 2011 ARC

High Cost of Point Solutions

“Organizations that choose individual solutions (people,

policies, procedures or technology) for each regulatory challenge they face will spend 10x more on compliance and governance than those that

leverage each implementation for multiple requirements”

Gartner Symposium ITxpo October 2005

So, do you want this?

ARC PROPRIETARY AND CONFIDENTIAL. This document includes confidential information that is proprietary to Airlines Reporting Corporation (ARC). Disclosure of this document or any information contained herein to third parties is prohibited without the prior written consent of an authorized ARC officer. Obsolete versions of this document should be destroyed in a manner to prevent compromise of the information, e.g., shredding. 5

Page 7: Becky Briggs, BSMP, CMQ/OE, CBIP Director/Data Steward ARC May 10, 2011 Data Governance How to Keep Your DG Program Viable for the Long Haul.

© 2011 ARC

High Cost of Point Solutions

“Organizations that choose individual solutions (people,

policies, procedures or technology) for each regulatory challenge they face will spend 10x more on compliance and governance than those that

leverage each implementation for multiple requirements”

Gartner Symposium ITxpo October 2005

Or this?

ARC PROPRIETARY AND CONFIDENTIAL. This document includes confidential information that is proprietary to Airlines Reporting Corporation (ARC). Disclosure of this document or any information contained herein to third parties is prohibited without the prior written consent of an authorized ARC officer. Obsolete versions of this document should be destroyed in a manner to prevent compromise of the information, e.g., shredding. 5

Page 8: Becky Briggs, BSMP, CMQ/OE, CBIP Director/Data Steward ARC May 10, 2011 Data Governance How to Keep Your DG Program Viable for the Long Haul.

© 2011 ARC

An Evolutionary Approach

2002DW ImplementationInitial Data Share PoliciesSystem Data ModelingSystem Data Mapping

2003Data Stewardship ProgramLDM & PDM Processes

2004Chief Security Officer AddedEU Safe HarborBusiness Continuity IntroducedETL Tool IntroducedData Architects Added

2005Data Correction Process FormalizedData Profiling Tool AddedPCI Compliance AchievedDual Active DR ImplementedData Acquisition Strategy

2006Enterprise Architecture ImplementedData Provisioning IntroducedData Quality & Integration Tools StandardizedData Models Capture Business & Technical detailsData Incident Reporting Formalized

2007Begin to Standardize Data Definitions and Business RulesFormalize Data SLAs Internally & Externally

2008TDWI Best Practice Award for Data Governance

2009Integrated CRM Implemented

Airlines Reporting Corporation

2008 CATEGORY WINNERDATA GOVERNANCE

Non-Existent Ad Hoc Standardized Committed Consolidated Strategic

2010Metadata Strategy Proposed – in review – implementation TBDChief Risk Officer Added

ARC PROPRIETARY AND CONFIDENTIAL. This document includes confidential information that is proprietary to Airlines Reporting Corporation (ARC). Disclosure of this document or any information contained herein to third parties is prohibited without the prior written consent of an authorized ARC officer. Obsolete versions of this document should be destroyed in a manner to prevent compromise of the information, e.g., shredding.

2011DG Integrated into Strategy, BSC, Risk MapBegin Work for ISO 27001

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Page 9: Becky Briggs, BSMP, CMQ/OE, CBIP Director/Data Steward ARC May 10, 2011 Data Governance How to Keep Your DG Program Viable for the Long Haul.

© 2011 ARC

Keeping Your DG Program Viable & Relevant

Move to Strategic Maturity – see DG as a Strategic Priority

> Put mechanisms in place to detect trends & patterns and react to them to gain new capabilities

> Show agility while maintaining necessary controls> Improve capabilities of individuals and groups across the

DG program (create a “volunteer army”)> Meet the evolving needs of the organization> DG as part of the Corporate Strategy Map, BSC,

Strategic Initiatives, & on the Corporate Risk Map> Be seen as strategic, visible, impactful, relevant and

part of the corporate culture> Deliver value to the organization

ARC PROPRIETARY AND CONFIDENTIAL. This document includes confidential information that is proprietary to Airlines Reporting Corporation (ARC). Disclosure of this document or any information contained herein to third parties is prohibited without the prior written consent of an authorized ARC officer. Obsolete versions of this document should be destroyed in a manner to prevent compromise of the information, e.g., shredding.

Non-Existent Ad Hoc Standardized Committed Consolidated Strategic

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Page 10: Becky Briggs, BSMP, CMQ/OE, CBIP Director/Data Steward ARC May 10, 2011 Data Governance How to Keep Your DG Program Viable for the Long Haul.

© 2011 ARC

Balance across competing goals

> Compliance goals that may limit data access vs. business needs that require expanded data access

> Learning that the business goals must drive IT for overall strategic success

> Data ownership challenges between the individual departments and the enterprise

> Integrating data governance into many different business initiatives

> Seeing data governance as a resource to move the organization forward, not as a role or headcount issue

It’s a Balancing Act

ARC PROPRIETARY AND CONFIDENTIAL. This document includes confidential information that is proprietary to Airlines Reporting Corporation (ARC). Disclosure of this document or any information contained herein to third parties is prohibited without the prior written consent of an authorized ARC officer. Obsolete versions of this document should be destroyed in a manner to prevent compromise of the information, e.g., shredding. 8

Page 11: Becky Briggs, BSMP, CMQ/OE, CBIP Director/Data Steward ARC May 10, 2011 Data Governance How to Keep Your DG Program Viable for the Long Haul.

© 2011 ARC

Three P’s and a T

People Proc

edur

es

Policies

Technology

Policies – Data Sharing Rules, PCI Compliance, Antitrust

Procedures – Data Acquisition, Data Quality, Data Profiling

People – Access, Usage Rules, Data Stewardship

Technology – Data Quality, ETL, Meta Data

ARC PROPRIETARY AND CONFIDENTIAL. This document includes confidential information that is proprietary to Airlines Reporting Corporation (ARC). Disclosure of this document or any information contained herein to third parties is prohibited without the prior written consent of an authorized ARC officer. Obsolete versions of this document should be destroyed in a manner to prevent compromise of the information, e.g., shredding. 9

Page 12: Becky Briggs, BSMP, CMQ/OE, CBIP Director/Data Steward ARC May 10, 2011 Data Governance How to Keep Your DG Program Viable for the Long Haul.

© 2011 ARC

ARCs Data Governance Business Model

ARC Business Information Model

Meta Data Management

Data Sourcing

and Staging

Data Quality

ETL EDW

Data MartsBI

Operations, Audit & Security

ARC PROPRIETARY AND CONFIDENTIAL. This document includes confidential information that is proprietary to Airlines Reporting Corporation (ARC). Disclosure of this document or any information contained herein to third parties is prohibited without the prior written consent of an authorized ARC officer. Obsolete versions of this document should be destroyed in a manner to prevent compromise of the information, e.g., shredding. 10

Page 13: Becky Briggs, BSMP, CMQ/OE, CBIP Director/Data Steward ARC May 10, 2011 Data Governance How to Keep Your DG Program Viable for the Long Haul.

© 2011 ARC

ARCs Data Governance Business Model

ARC Business Information Model

Ab Initio EME Meta Data Management

Data Sourcing

and Staging

Ab Initio Data

Profiler

Ab Initio ETL

Teradata & TD Data

Marts

BI (MSTR SAS

TD SQL)

Operations, Audit & Security

ARC PROPRIETARY AND CONFIDENTIAL. This document includes confidential information that is proprietary to Airlines Reporting Corporation (ARC). Disclosure of this document or any information contained herein to third parties is prohibited without the prior written consent of an authorized ARC officer. Obsolete versions of this document should be destroyed in a manner to prevent compromise of the information, e.g., shredding.

DG has executive level sponsorship

Business Users own data strategy

and deliveryPolicies &

Procedures are in place (may be

automated)

New initiatives follow the

Information Model

Business Rules shared

component

Business Definitions Bus/Op Metadata

Work Flows

All tools are standardized

across organization

Data Stewardship

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Page 14: Becky Briggs, BSMP, CMQ/OE, CBIP Director/Data Steward ARC May 10, 2011 Data Governance How to Keep Your DG Program Viable for the Long Haul.

© 2011 ARC

ARCs Data Governance Business Model

ARC Business Information Model

Meta Data Management

Data Sourcing

and Staging

Ab Initio Data

Profiler

Ab Initio ETL

Teradata & TD Data

Marts

BI (MSTR SAS

TD SQL)

Operations, Audit & Security

ARC PROPRIETARY AND CONFIDENTIAL. This document includes confidential information that is proprietary to Airlines Reporting Corporation (ARC). Disclosure of this document or any information contained herein to third parties is prohibited without the prior written consent of an authorized ARC officer. Obsolete versions of this document should be destroyed in a manner to prevent compromise of the information, e.g., shredding.

Built Business Case for Meta Data

Management

Integrating into EA Infrastructure/Future

State

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Page 15: Becky Briggs, BSMP, CMQ/OE, CBIP Director/Data Steward ARC May 10, 2011 Data Governance How to Keep Your DG Program Viable for the Long Haul.

© 2011 ARC

ARCs Data Governance Business Model

ARC Business Information Model

Ab Initio EME Meta Data Management

Data Sourcing

and Staging

Ab Initio Data

Profiler

Ab Initio ETL

Teradata & TD Data

Marts

BI (MSTR SAS

TD SQL)

Operations, Audit & Security

ARC PROPRIETARY AND CONFIDENTIAL. This document includes confidential information that is proprietary to Airlines Reporting Corporation (ARC). Disclosure of this document or any information contained herein to third parties is prohibited without the prior written consent of an authorized ARC officer. Obsolete versions of this document should be destroyed in a manner to prevent compromise of the information, e.g., shredding.

Data Hub Technology receives and disperses

data as required/defined

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Page 16: Becky Briggs, BSMP, CMQ/OE, CBIP Director/Data Steward ARC May 10, 2011 Data Governance How to Keep Your DG Program Viable for the Long Haul.

© 2011 ARC

ARCs Data Governance Business Model

ARC Business Information Model

Ab Initio EME Meta Data Management

Data Sourcing

and Staging

Ab Initio ETL

Teradata & TD Data

Marts

BI (MSTR SAS

TD SQL)

Operations, Audit & Security

ARC PROPRIETARY AND CONFIDENTIAL. This document includes confidential information that is proprietary to Airlines Reporting Corporation (ARC). Disclosure of this document or any information contained herein to third parties is prohibited without the prior written consent of an authorized ARC officer. Obsolete versions of this document should be destroyed in a manner to prevent compromise of the information, e.g., shredding.

Shared, flexible validation rules Integrated as part

of the overall model

Rigorously enforced to ward against bad dataExtensive

exception handling

Data Profiling On-Going Monitoring Data is continuously

inspected and issues resolved

Data Quality

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Page 17: Becky Briggs, BSMP, CMQ/OE, CBIP Director/Data Steward ARC May 10, 2011 Data Governance How to Keep Your DG Program Viable for the Long Haul.

© 2011 ARC

ARCs Data Governance Business Model

ARC Business Information Model

Meta Data Management

Data Sourcing

and Staging

Data Quality

ETL EDW

Data MartsBI

Operations, Audit & Security

ARC PROPRIETARY AND CONFIDENTIAL. This document includes confidential information that is proprietary to Airlines Reporting Corporation (ARC). Disclosure of this document or any information contained herein to third parties is prohibited without the prior written consent of an authorized ARC officer. Obsolete versions of this document should be destroyed in a manner to prevent compromise of the information, e.g., shredding.

Extract required data from source

Transform based on shared

business rules

Load to the source systems

Started out using home grown

solution

Moved to an ETL Suite with an ROI

of less than 2 years

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Page 18: Becky Briggs, BSMP, CMQ/OE, CBIP Director/Data Steward ARC May 10, 2011 Data Governance How to Keep Your DG Program Viable for the Long Haul.

© 2011 ARC

ARCs Data Governance Business Model

ARC Business Information Model

Meta Data Management

Data Sourcing

and Staging

Data Quality

ETL EDW

Data MartsBI

Operations, Audit & Security

ARC PROPRIETARY AND CONFIDENTIAL. This document includes confidential information that is proprietary to Airlines Reporting Corporation (ARC). Disclosure of this document or any information contained herein to third parties is prohibited without the prior written consent of an authorized ARC officer. Obsolete versions of this document should be destroyed in a manner to prevent compromise of the information, e.g., shredding.

Global Travel Industry Data Warehouse

Part Deux

Multiple Data Marts to support functional areas

Data Marts Built on Data Management

Model Infrastructure

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Page 19: Becky Briggs, BSMP, CMQ/OE, CBIP Director/Data Steward ARC May 10, 2011 Data Governance How to Keep Your DG Program Viable for the Long Haul.

© 2011 ARC

ARCs Data Governance Business Model

ARC Business Information Model

Meta Data Management

Data Sourcing

and Staging

Data Quality

ETL EDW

Data MartsBI

Operations, Audit & Security

ARC PROPRIETARY AND CONFIDENTIAL. This document includes confidential information that is proprietary to Airlines Reporting Corporation (ARC). Disclosure of this document or any information contained herein to third parties is prohibited without the prior written consent of an authorized ARC officer. Obsolete versions of this document should be destroyed in a manner to prevent compromise of the information, e.g., shredding.

Multiple BI tools to support users

BI Metadata Built on Data Management

Infrastructure Model

Data/Information ‘Built on the Fly’ is a challenge and must use shared

services

Added Functionality of

Data Visualization

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Page 20: Becky Briggs, BSMP, CMQ/OE, CBIP Director/Data Steward ARC May 10, 2011 Data Governance How to Keep Your DG Program Viable for the Long Haul.

© 2011 ARC

ARCs Data Governance Business Model

ARC Business Information Model

Meta Data Management

Data Sourcing

and Staging

Data Quality

ETL EDW

Data MartsBI

Operations, Audit & Security

ARC PROPRIETARY AND CONFIDENTIAL. This document includes confidential information that is proprietary to Airlines Reporting Corporation (ARC). Disclosure of this document or any information contained herein to third parties is prohibited without the prior written consent of an authorized ARC officer. Obsolete versions of this document should be destroyed in a manner to prevent compromise of the information, e.g., shredding.

Audits – who did what, when and why?

Model, data, DG process itself

Role based security, robust

access management, sensitive data management

Operations stay in sync with DG

Business Model

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Page 21: Becky Briggs, BSMP, CMQ/OE, CBIP Director/Data Steward ARC May 10, 2011 Data Governance How to Keep Your DG Program Viable for the Long Haul.

© 2011 ARC

Keeping Your DG Program Viable & Relevant

Move to Strategic Maturity – see DG as a Strategic Priority

> DG as part of the Corporate Strategy Map, BSC, Strategic Initiatives, & on the Corporate Risk Map

> Be seen as strategic, visible, impactful, relevant and part of the corporate culture

> Deliver value to the organization

ARC PROPRIETARY AND CONFIDENTIAL. This document includes confidential information that is proprietary to Airlines Reporting Corporation (ARC). Disclosure of this document or any information contained herein to third parties is prohibited without the prior written consent of an authorized ARC officer. Obsolete versions of this document should be destroyed in a manner to prevent compromise of the information, e.g., shredding.

Non-Existent Ad Hoc Standardized Committed Consolidated Strategic

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Page 22: Becky Briggs, BSMP, CMQ/OE, CBIP Director/Data Steward ARC May 10, 2011 Data Governance How to Keep Your DG Program Viable for the Long Haul.

© 2011 ARC

Keeping Your DG Program Viable & RelevantStrategic Plan

ARC PROPRIETARY AND CONFIDENTIAL. This document includes confidential information that is proprietary to Airlines Reporting Corporation (ARC). Disclosure of this document or any information contained herein to third parties is prohibited without the prior written consent of an authorized ARC officer. Obsolete versions of this document should be destroyed in a manner to prevent compromise of the information, e.g., shredding.

Non-Existent Ad Hoc Standardized Committed Consolidated Strategic

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Page 23: Becky Briggs, BSMP, CMQ/OE, CBIP Director/Data Steward ARC May 10, 2011 Data Governance How to Keep Your DG Program Viable for the Long Haul.

© 2011 ARC

Keeping Your DG Program Viable & RelevantBalanced ScoreCard

ARC PROPRIETARY AND CONFIDENTIAL. This document includes confidential information that is proprietary to Airlines Reporting Corporation (ARC). Disclosure of this document or any information contained herein to third parties is prohibited without the prior written consent of an authorized ARC officer. Obsolete versions of this document should be destroyed in a manner to prevent compromise of the information, e.g., shredding.

Non-Existent Ad Hoc Standardized Committed Consolidated Strategic

Financial Perspective:Significant % Revenue is tied to the creation of quality data products

& services

Customer Perspective:(Seen as) Secure & Trusted – PCI, Safe Harbor, ISO

Process Perspective:Develop Quality Products & Services

Build the Premier Source of Global Travel DataProactively Manage Risk (DG Program is on the Risk Map)

Learning Perspective:Develop Skills for the Future

Maintain an Innovative, Performance-Based Culture

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Page 24: Becky Briggs, BSMP, CMQ/OE, CBIP Director/Data Steward ARC May 10, 2011 Data Governance How to Keep Your DG Program Viable for the Long Haul.

© 2011 ARC

Mature DG Offers a Competitive Advantage

InternallyEfficiencies across the board

Common SoftwareEmbedded Enterprise Data Governance

Common Policies and ProceduresMeasurements and Changes Managed

ExternallySeen as a Leader in Data Governance (Best Practice

Awards)RFP Responses (PCI Compliance, Safe Harbor)

ARC PROPRIETARY AND CONFIDENTIAL. This document includes confidential information that is proprietary to Airlines Reporting Corporation (ARC). Disclosure of this document or any information contained herein to third parties is prohibited without the prior written consent of an authorized ARC officer. Obsolete versions of this document should be destroyed in a manner to prevent compromise of the information, e.g., shredding. 22

Page 25: Becky Briggs, BSMP, CMQ/OE, CBIP Director/Data Steward ARC May 10, 2011 Data Governance How to Keep Your DG Program Viable for the Long Haul.

© 2011 ARC

Next Steps for ARC

Metadata Impact Analysis

Business Rules Engine

Information Architects

Automated Policies

Continuous Data Inspection

Next Generation Governance

ARC PROPRIETARY AND CONFIDENTIAL. This document includes confidential information that is proprietary to Airlines Reporting Corporation (ARC). Disclosure of this document or any information contained herein to third parties is prohibited without the prior written consent of an authorized ARC officer. Obsolete versions of this document should be destroyed in a manner to prevent compromise of the information, e.g., shredding. 23

Page 26: Becky Briggs, BSMP, CMQ/OE, CBIP Director/Data Steward ARC May 10, 2011 Data Governance How to Keep Your DG Program Viable for the Long Haul.

© 2011 ARC

ARC Best Practices to Share

Develop a data-driven company cultureData Governance practices must be repeatable and easily integrated from

project to projectProvide a foundation that is scalable and

modeled with an enterprise viewStrong relationships between IS and the

business must exist (or be established)

On-going relationship building with external suppliers is a requirement

(via SLAs)

ARC PROPRIETARY AND CONFIDENTIAL. This document includes confidential information that is proprietary to Airlines Reporting Corporation (ARC). Disclosure of this document or any information contained herein to third parties is prohibited without the prior written consent of an authorized ARC officer. Obsolete versions of this document should be destroyed in a manner to prevent compromise of the information, e.g., shredding.

Create a data management strategyStrong audit and corporate

responsibility focusTop down/Bottom up concurrent focus

needed for continued successCreate the ability to access data needs

across organizational silosStrong internal employee training program on policies and proceduresRemember Data Governance is a program, not a project – you’re on a multi-year journey – enjoy the ride

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Page 27: Becky Briggs, BSMP, CMQ/OE, CBIP Director/Data Steward ARC May 10, 2011 Data Governance How to Keep Your DG Program Viable for the Long Haul.

© 2011 ARC

Questions?

ARC PROPRIETARY AND CONFIDENTIAL. This document includes confidential information that is proprietary to Airlines Reporting Corporation (ARC). Disclosure of this document or any information contained herein to third parties is prohibited without the prior written consent of an authorized ARC officer. Obsolete versions of this document should be destroyed in a manner to prevent compromise of the information, e.g., shredding. 25

Page 28: Becky Briggs, BSMP, CMQ/OE, CBIP Director/Data Steward ARC May 10, 2011 Data Governance How to Keep Your DG Program Viable for the Long Haul.

© 2011 ARC

Becky Briggs, BSMP, CMQ/OE, CBIP

Data StewardDirector – Office of Strategic Management

[email protected]

770.870.0462

ARC PROPRIETARY AND CONFIDENTIAL. This document includes confidential information that is proprietary to Airlines Reporting Corporation (ARC). Disclosure of this document or any information contained herein to third parties is prohibited without the prior written consent of an authorized ARC officer. Obsolete versions of this document should be destroyed in a manner to prevent compromise of the information, e.g., shredding. 26