The definition of personal data in the Hong Kong Privacy Ordinance (PDPO) is broad and includes any information that can be used to identify a living person. This can include a name, identity card number or other identification number, location data, or online identifiers. It can also include factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person. It can also include information about legal entities such as companies and trusts.
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When implementing data governance, you’ll need to involve many people. Even if your actual governance team is small, a data governance program impacts lots of people—customers, partners, employees, etc. That means they’re going to have opinions, and some of them are likely to be very vocal about those opinions. To avoid conflict and confusion, it’s important to establish an organized approach for communicating responsibilities, which can be accomplished with the help of a responsibility assignment matrix like RACI (responsible, accountable, consult, informed).
A strong business case will set out your vision for what you want your governance program to achieve. It will also define the roles, responsibilities and processes that you’ll need to implement to deliver on your vision. This is a key step in building a framework for success that will drive adoption and measurable return on investment.
In terms of the people you need on your governance team, the most critical role is the data steward. This is the person who is the bridge between business and IT. Ideally, they’re experienced business analysts who have an in-depth understanding of the technology and processes that support their organization’s business activities. They should be able to translate how your governance framework will affect these business processes and decisions, and they’ll be the primary point of escalation for issues or problems.
Lastly, you’ll need a data governance leader who can coordinate tasks for the stewards and communicate decisions made by them. This role can be filled by the stewards themselves, or by someone else who has the appropriate knowledge and skills to take on this responsibility. It’s important to have this position in place to drive ongoing data audits and metrics that assess your program’s performance, as well as ensure compliance with the PDPO. It’s important to remember that your governance framework is a living document, so you should periodically review it and revise it as necessary. This will ensure that it is continually aligned to your business goals.