Data Governance and Taxes
When I received a stock "cliff" award, the stock was not granted for three years; for those three years, I paid no taxes on the award. This year, the award matured, and I was surprised when I received my statement as it was 40% less than expected. After reading the statement, I discovered the company sold stock to pay for federal income tax and social security withholdings; I received the remainder. I had forgotten 'my' stock was subject to other rules and regulations.
The business may believe they "own" the process and the data, but they do not. There is a reason the term 'Steward' is used to represent the Business Owners. Stewardship is the "careful and responsible management of something entrusted in one's care." The business may believe they "own" the data and process; they do not. They are Stewards of the data and the process.
Just as my stock was subject to federal and state rules, so the data is subject to external international, federal, state, and other organization rules. Most companies have internal rules regarding how data is defined, can be used, is protected. These are collectively referred to as "Data Governance." Today's Business Analyst needs to be aware of and engaged in Data Governance early in the analysis.
Depending upon the organization, Data Governance may be informal or formal, but the goals are the same:
- Increase data quality
- Meet internal and external data restrictions
A Business Analyst needs to ensure data quality business rules are included in every analysis; examples of data quality rules would be those needed to ensure accuracy, completeness, and validity. I once worked on a project with international data, and the BA did not capture the corporate rule that all financial data was to be converted to US dollars. It was discovered only when a "profit" dissolved because Italian lira was being used.
The BA needs to be aware of and engage the internal Data Governance stakeholders early in the analysis. This will include, at a minimum, the Data Governance group (if one exists), the Security team, and the Legal department. These groups can provide guidance for any federal and state laws that may apply. If the organization has an overseas office, the data may also be impacted by Federal Trade Commission data export rules. For example, even if the data resides onshore in the United States, depending upon what the data represents there may be restrictions for access by an offshore team. There may also be external organization rules that need to be captured; for example, if taking a credit card payment, the Payment Card Industry rules may need to be incorporated.
Pleading ignorance to pay taxes will not allow me to avoid penalties with the IRS. Pleading ignorance of the Data Governance rules will not be an acceptable excuse for an application requiring rework!
In the words of William A. Foster:
"Quality is never an accident; it is always the result of high intention, sincere effort, intelligent direction and skillful execution…"
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