A supervisory finding turned into an investment budget for data
A financial institution in Colombia received a finding from its supervisor and had three months to answer it with a data governance policy. It had no one in-house who had done this. The board approved the policy within the deadline, and its roadmap unlocked an investment budget.
The problem
The CTO had a contract under way, with an agreed scope and schedule. In the middle of it came a finding from the supervisor that forced the data governance policy to be brought forward. Three months, a date that was not negotiable, and none of it up to him.
Nobody on the internal team had done data governance before. There were people who knew the systems, but no one had written a policy that had to hold up in front of a regulator and be approved by the board. Learning on the way did not fit in the deadline.
There was also a problem that had not yet been named. The institution had been funding its data out of the operating budget. Nobody had put a number on what closing the gap would cost, so there was no figure to take to the committee either.
What we did
We started with the diagnosis. We established a baseline of what the institution already had in data governance and data management, so as to build on that rather than on a blank page. In parallel we mapped the stakeholders with the client team and worked out what the regulatory requirement actually demanded, which was not the same as what the team assumed it demanded.
From there we designed the policy. We adapted DAMA-DMBOK2 and the Colombian State enterprise architecture framework to the institution’s corporate model, and articulated it with the institutional policies already in force so that it would not compete with them. The policy set out roles, decision-making bodies at three levels, and review cycles on an enforceable schedule.
The third block was approval, which is where this kind of work usually dies. We took the document through the operational, tactical and strategic levels, addressing comments in each round, all the way to the board. All of it inside the three months. The institution supplied its information and its people; we supplied the expertise it did not have in house and carried the full review cycle.
What changed
The board approved the policy within the regulatory deadline, with a formal mandate rather than as a reference document.
The deeper effect was a different one. In costing the roadmap, the institution saw that it was treating its data as an operating expense when what it needed was investment. That distinction changed the budget conversation. The roadmap was structured as a programme of three projects and became the basis for a USD 2 500 000 investment, now under way.