Data governance is both an organizational process and a structure. Data governance establishes responsibility for data, organizing program staff to collaboratively and continuously improve data quality through the creation and enforcement of policies, roles, responsibilities, and procedures. Management is the development, implementation, and enforcement of policies and procedures (standardization of business processes) to operationalize all aspects of the data system. Management addresses the implementation of data governance policies (via procedures) and oversees the use and operation of the data system.
Data governance exists whether formal or informal. Informal data governance is associated with significant risks. These risks may include:
- questionable data quality, security, and usefulness
- difficulty in maintaining consistent and reliable data and processes;
- unclear roles and responsibilities of internal and external staff relative to the data; and
- inappropriate data sharing with internal and external staff and across external agencies.
Formal data governance exists in written form. The benefits of formal data governance include:
- increased likelihood that data are of high quality and protected;
- increased use of data in ways consistent with the purpose and vision of the data system;
- increased confidence in data and associated processes (e.g., oversight of analysis activities); and
- improved management, including fiscal efficiency and overall system accountability.
Data governance structures and policies are dynamic ; they must evolve as the programs and policies that drive the data system evolves. They must also be consistent with applicable federal and state regulations and policies. Managing the state data system requires responding to the evolving structures and policies and implementing the associated procedures. Part C and Part B 619 state staff or other designated state staff should be actively engaged in the governance of their data system. (In some states, there may be more than one data governance structure overseeing data that impact Part C/619.)
This subcomponent consists of three sections. The first section, Authority and Accountability, is about establishing the data governance and management structure(s), responsibility, and oversight. The second section, Data Quality and Integrity, addresses policies to ensure data quality (timeliness, completeness, accuracy and reliability) and integrity (maintaining data quality and consistency for data’s intended use throughout their lifecycle). The section also focuses on the implementation of the procedures to ensure consistent application of data quality and integrity policies. The third section, Security and Access, focuses on ensuring appropriate access and the protection of state data from loss, misuse, and contamination.
Section 1: Authority and Accountability
Quality Indicator DG1
The state’s data governance delineates appropriate roles and responsibility for decision-making authority, accountability, and management consistent with the uses of the Part C/619 data system.
|DG1 – Elements of Quality|
|DG1a||State-level, formalized data governance structure exists to facilitate necessary decisions about the Part C/619 data system|
|DG1b||Data governance structure includes representation/input from Part C/619 state program staff who have decision-making authority.|
|DG1c||Data governance structure oversees all data collected and maintained by Part C/619 and ensures adherence to governance policies related to Part C/619 data, regardless of where the data are located.|
|DG1d||Written statement(s) delineates decision-making authority for Part C/619 data governance.|
|DG1e||All data-related responsibilities associated with the Part C/619 state data system(s) are clearly delineated and assigned to responsible and informed parties (e.g., data manager, data steward, data owner).|
|DG1f||Information about data governance decision-making authority is communicated to staff and stakeholders (e.g., dissemination of organizational chart, data sharing agreements).|
|DG1g||Data governance structure and authority applicable to Part C/619 are reviewed and revised as needed with input from Part C/619.|
Quality Indicator DG2
Part C/619 staff and other state staff develop and implement data governance policies and procedures to effectively manage the data system.
|DG2 – Elements of Quality|
|DG2a||Data governance policies and procedures are aligned with the purpose and vision of the Part C/619 data system.|
|DG2b||Data governance policies and procedures adhere to all federal (e.g., IDEA, FERPA, HIPAA), state, and local laws, regulations, and align with standards.|
|DG2c||Data governance policies are developed with input from different groups of stakeholders as relevant.|
|DG2d||Processes are in place to allow Part C/619 staff and other state staff to recommend and provide input on relevant policy and procedural changes (e.g., new or revised data collection requirements, federal regulation change, changes to how external requests for data are addressed).
DG2e. Data governance policies and procedures address Part C/619 data oversight and accountability.
|DG2f||Data governance policies and procedures are communicated to staff and stakeholders.|
|DG2g||Data governance policies address Part C/619 representation on other data governance structures (e.g., SLDS, ECIDS, lead agency governance committee) in relation to Part C/619 state data.|
|DG2h||Data governance policies and procedures address responding to Part C/619 data requests.|
|DG2i||Data governance policies and procedures are periodically reviewed and revised as needed.|
Section 2: Data Quality and Integrity
Quality Indicator DG3
Data governance policies and procedures address the quality and integrity of the data.
|DG3 – Elements of Quality|
|DG3a||Data governance policies and procedures address timeliness, completeness, accuracy, and reliability aspects of Part C/619 data.|
|DG3b||Data governance policies and procedures address maintaining data quality and consistency for Part C/619 data’s intended use throughout its lifecycle.|
|DG3c||Data governance policies and procedures require all staff and contractors who collect, maintain, and/or receive Part C/619 data to participate in ongoing data quality and integrity training.|
|DG3d||Data governance policies and procedures require that any internal or external program or agency maintaining and/or using state Part C/619 data adhere to applicable data quality and integrity policies and procedures.|
|DG3e||Data governance policies and procedures require documentation that addresses data integrity when transferring state Part C/619 data to other programs or agencies.|
|DG3f||Data governance policies and procedures require Part C/619 data are retained and destroyed according to applicable federal, state, and agency requirements.|
Quality Indicator DG4
Part C/619 or other state staff oversee and manage the consistent application of data quality and integrity policies and procedures.
|DG4 – Elements of Quality|
|DG4a||Data quality and integrity policies and procedures are regularly communicated to system users.|
|DG4b||Standardized training materials are created and maintained for Part C/619 data system quality operations.|
|DG4c||Data quality trainings are regularly conducted for data managers at the state and local levels.|
|DG4d||Data are regularly reviewed for timeliness, completeness, accuracy, and reliability for improvement purposes.|
|DG4e||Data quality and integrity procedures are adhered to when Part C/619 data are transferred or shared.|
Section 3: Security and Access
Quality Indicator DG5
Data governance policies and procedures address the security of and access to Part C/619 data.
|DG5 – Elements of Quality|
|DG5a||Data governance policies and procedures document and support secure data system operations (e.g., data security, data storage, back-up, recovery, transmission, destruction, role-based permissions).|
|DG5b||Data governance policies and procedures document and support authorized user access and include specific data system user practices (e.g., signed data system user agreements, password strength and authentication, acceptable use of personal devices, timely removal of user access when role changes or employment ends).|
|DG5c||Data governance policies and procedures require that all IT and program staff (including contractors) who collect, maintain, or receive Part C/619 data participate in periodic training about applicable data security and access.|
|DG5d||Data governance policies and procedures require adherence to security and access requirements when transferring or sharing Part C/619 state data.|
|DG5e||Data governance policies delineate procedures in response to a Part C/619 data breach.|
Quality Indicator DG6
Part C/619 or other state staff oversee and manage the consistent application of data security and access policies and procedures.
|DG6 – Elements of Quality|
|DG6a||Data security and access policies and procedures are regularly communicated to data system users.|
|DG6b||Regular monitoring and testing are conducted on the overall security of and access to the Part C/619 data system.|
|DG6c||Methods are in place to ensure that all users with access to state Part C/619 data adhere to security and access policies and procedures.|
|DG6d||Security procedures are monitored when transferring or sharing Part C/619 data.|
|DG6e||Standardized training materials are created, used, and maintained that address procedures and responsibility for Part C/619 data system security, access operations, and data use.|
Resources Related to Data Governance and Management
- Data Governance ToolkitThis DaSy toolkit contains information, guidance, and templates to assist Part C and Part B 619 program staff with creating or enhancing their data governance ...Read more
- Data Governance ChecklistThis 2011 checklist is designed to assist stakeholder organizations with establishing and maintaining a successful data governance program by summarizing the key data privacy and ...Read more
- P-20W Data Governance: Tips from the StatesThis 2012 resource, updated in 2017, includes best practices and lessons learned from SLDS grantee states on establishing data governance for data systems spanning early ...Read more
- A Framework for Choosing a State-Level Early Childhood Governance SystemA number of states have made ambitious governance changes that involve creating new agencies focused on early childhood programs and services for children from birth ...Read more
- Avoid the Pitfalls: Benefits of Formal Part C Data System GovernanceThis 2016 brief promotes formal data governance for Part C data by describing lessons learned from other industries; outlining the risks of informal data governance ...Read more
- Traveling Through Time: The Forum Guide to Longitudinal Data Systems (Book III)This 2011 electronic book is the third in a four-part series about longitudinal data systems. It provides guidance on organizational issues, how to keep the ...Read more
Published March 2022.