Designing And Implementing Information Governance In Financial Services Industry

Organizations for information governance

There is a great realization of the importance of information governance across all industries. However, there are specific aspects or characteristics of information governance which are considered unique to a particular discipline or industry (Reinecke & Australia, 2010). Furthermore, even within the same industry, information governance must be tailored in order to fit the unique and particular needs of every organization. This paper focusses particularly on the financial services industry, which is believed to have been undergoing transformational changes which are significantly comprehensive. According to Axelrod, Bayuk & Schutzer (2009), financial service professionals are consequently faced with new requirements and regulations that make effective information governance essential. Having been appointed the vice president and chief financial officer for National City Financial Services Corporation, it has been necessary to design and implement a formal information governance program for the organization (Giordano, 2015). The main purpose of this paper is to discuss the overall plan and steps that should be taken in order to implement information governance in the organization (Axelrod, Bayuk & Schutzer, 2009).

1. Different Organizations, Associations, Affiliates and Accrediting Agencies Who Can Provide Guidance on the Implementation of Information Governance in the Financial Services Industry

Information governance is the framework that is stablished by organizations for purposes of enabling it handle personal or individual information in a manner that is secure and confidential, so that ethical and quality standards are appropriately upheld (Giordano, 2015). After conducting necessary research, there are various organizations, affiliates, associations and accrediting agencies from whom National City Financial Services Corporation may seek guidance on implementing information governance (Rajola, 2013). These are discussed below.

1. FTI Consulting

This information governance consultancy firm has over a decade of experience in matters related to information guidance, data security, e-discovery and investigations as well (Reinecke & Australia, 2010). The Information Governance, Privacy and Security team of this consultancy firm is comprised of practitioners who have a wide range of security, legal and technological certifications. Examples of these certifications are Access Data Certified Examiner, ACEDS, Exterro Platform Administrator and Ringtail Administrator certification among others (Rajola, 2013).

1. Galaxy Consulting

This company has information governance services which include development of strategic and meaningful approach to implementation of information governance for an organization (Rajola, 2013). It helps clients in developing and implementing set policies, roles, processes, controls and metrics with regard to information governance (SMALLWOOD, 2018).

• Assent Risk Management

This consulting company has a team of information governance consultants who are experienced and can provide advice on procedures, policies, controls and processes that are necessary for helping organizations protect their data and key information (Rajola, 2013).

1. Contoural Strategic Information Governance Consultants

This consulting firm offers document storage services as well as data discovery services. It has experienced team of consultants who have expertise of more that fifteen ears (Axelrod, Bayuk & Schutzer, 2009). The company has served more than five hundred clients and federal agencies as well as public entities (Reinecke & Australia, 2010). 

1. Consilio

This company offers a variety of services among them design and implementation of information governance strategies. It provides clients with foundational infrastructure of policies on governance, retention procedures and schedules which can be used by organizations in building their future information management related implementation (Rajola, 2013). 

1. Tasks/Steps/Order for Designing and Implementing an Information Governance (IG) Program

The following are the five major steps that can be adopted for designing and implementing an Information Governance program for National City Financial services Corporation (Reinecke & Australia, 2010).

1. Review and Inspection

Steps for designing and implementing an Information Governance program

A critical review and analysis must be carried out in order to reveal weaknesses in the current information governance program of National City Financial services Corporation. This helps in gaining an understanding on how data is created within the organization, and is moved through its lifecycle before being disposed (Giordano, 2015).

1. Establishment of Common Best Practices

After a critical review is completed, the information governance team must have identified some of the practices that are considered to have been working properly for the company. These practices will be used for providing a foundation on which the information governance program will be rebuilt (Giordano, 2015).

• Clean Up and Migration

After the implementation team has pulled out some of the best practices, it should consider addressing some of the failures identified. For instance, the company must have identified obsolete and trivial data that is often unclassified and has a little value to the organization (Van & DeHaes, 2008). Location and assessment of this redundant, obsolete and trivial data is considered an important initiative prior to implementation of an information governance program. The team should then determine the proper classification of the data, and must classify it into its correct lifecycle. The organization can also consider performing a migration of part or whole of their data. This is done with an aim of having the organization’s data in a single repository (Giordano, 2015).

1. Implementation

This is the most last step which involves putting the plan into action. In order to have a successful implementation, executive buy-in is considered essential and critical. This involves engaging the top executive of the National City Financial services Corporation such as the Chief executive officer and the Human resource department, so that the program or policy can be adopted and followed with ease (Aronson, 2011).

1. Continuous Review and Evaluation

Upon implementation of the information governance program, it is important to make review and evaluate it continuously and regularly in order to identify any possible loopholes that may require to be sealed (Giordano, 2015). The Chief Financial Officer, with the help of the other executive members of National City Financial Services Corporation, needs to establish a methodology or approach of assessing whether or not the implemented IG program is working effectively as required for serving the sole purpose for which it was designed (Axelrod, Bayuk & Schutzer, 2009).

With regard to designing and implementing the information governance program for the company, the team members should be allocated various roles and responsibilities (Aronson, 2011). This is summarized in the table below.

However, it should be noted that the following will need to be completed or accomplished before the members begin their tasks of designing and implementing the information governance program (Van & DeHaes, 2008).

1. Understanding the various protocols for engaging staff and fellow team members.
2. Deploying relevant technologies to support the information governance team.

• Assessing the effectiveness of the design of the IG policies.

1. Performing privacy data risk assessments.

1. Federal and State Laws That Must Be Taken Into Consideration

The primary corporate office of National City Financial Services Corporation is located in Lexington, Kentucky. Therefore, it is very essential to be familiar with the federal and state laws that must be considered while designing and implementing an information governance program, as these may have a direct effect on the financial services industry (Axelrod, Bayuk & Schutzer, 2009). For instance, the implementation team must consider the requirement for financial institutions to protect their consumers with regard to depositories that exceed ten billion in assets. Additionally, depositories which are below ten billion are subject to various rules that are enforced by the prudential regulators of financial institutions in Kentucky (Axelrod, Bayuk & Schutzer, 2009).

Conclusion

Furthermore, financial institutions are required by the Bank Secrecy Act (BSA) to establish and implement minimum security procedures which are aimed at discouraging robberies and bank burglaries (Van & DeHaes, 2008). The top management of National City Financial Services Corporation must therefore consider implementing a program which complies with the Bank Secrecy Act (BSA), as required by the federal law (E-Discovery and Information Governance National Institute, American Bar Association & Center for Professional Development, 2013).

Additionally, the federal regulations for financial institutions and other industries in Kentucky requires financial firms and banks to comply with banking regulations and other government rules. For instance, the truth in lending Act (TILA) requires firms to protect their customers in their lending dealings. With this regard, financial institutions are required by this act to disclose all information which is regarded necessary for helping customers make an informed financial decision. Furthermore, financial institutions are required by the Fair and Accurate Credit Transactions Act (FACTA) to design and implement programs which help in improving the accredited records of consumers (E-Discovery and Information Governance National Institute, American Bar Association & Center for Professional Development, 2013). This act also requires banks and other financial institutions to issue risk based pricing notices and credit scores to clients in relation to denial or offer of less favorable credit terms. This act also has provisions which are designed for preventing and mitigating identity theft, which includes a section that can be used by clients to place fraud alerts in their files of credit (Axelrod, Bayuk & Schutzer, 2009).

Conclusion

As per the above discussion, information governance is essential for securing the key information of an organization. Due to the changing transformation in the financial services industry, there is an urgent need for National City Financial Services Corporation to design and implement an information governance program. The various steps that should be followed by the implementation team in achieving include review and inspection, establishment of best common practices, clean up and migration, implementation and continuous review and evaluation of the program (Axelrod, Bayuk & Schutzer, 2009). However, prior to implementing the program, various activities need to be accomplished. These include understanding the various protocols for engaging staff and fellow team members, deploying relevant technologies to support the information governance team, assessing the effectiveness of the design of the IG policies and performing privacy data risk assessments.

Endnotes

 Andrew Ackerman and Christina Rexrode. (2018, March 1). Senate Readies Rollback of Bank Rules. Accessed https://www.wsj.com/articles/senate-readies-rollback-of-bank-rules-1519900200

Department of Financial Institutions | Welcome. (2018, May 6). Accessed from https://kfi.ky.gov/Pages/default.aspx

Fair and Accurate Credit Transactions Act of 2003. (2016, July 24). Accessed https://www.ftc.gov/enforcement/statutes/fair-accurate-credit-transactions-act-2003

Truth in Lending Act (TILA)? Consumer Rights & Protections. (2018, June 3). Accessed https://www.debt.org/credit/your-consumer-rights/truth-lending-act/

References

Reinecke, I., & Australia. (2010). Independent review of implementation of the ICT Reform Program. Parkes, A.C.T: Dept. of Finance and Deregulation.

Axelrod, C. W., Bayuk, J. L., & Schutzer, D. (2009). Enterprise information security and privacy. Boston: Artech House.

Giordano, A. D. (2015). Performing information governance: A step-by-step guide to making information governance work. Upper Saddle River, NJ: IBM Press.

Rajola, F. (2013). Customer relationship management in the financial industry: Organizational processes and technology innovation. Berlin: Springer.

SMALLWOOD, R. O. (2018). INFORMATION GOVERNANCE: Concepts, strategies and best practices. S.l.: JOHN WILEY & SONS.

Van, G. W., & DeHaes, S. (2008). Implementing information technology governance: Models, practices, and cases. Hershey, PA: IGI Pub.

Aronson, B. (2011). Open Text Metastorm ProVision® 6.2 Strategy Implementation. Birmingham: Packt Pub.

E-Discovery and Information Governance National Institute, American Bar Association, & Center for Professional Development (American Bar Association). (2013). The 2013 E-Discovery and Information Governance National Institute. Chicago, IL: American Bar Association, Section of Science & Technology Law and Center for Professional Development.

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