Operationalise accountable data stewardship

Legal and policy context

Evidence Act Title II. Requires agencies to create open data plans, comprehensive inventories, and public engagement mechanisms. Stewardship councils must oversee data asset designations, prioritise publication schedules, and coordinate with statistical officials and evaluation officers.^{Public Law 115-435}

OMB M-19-23 and Federal Data Strategy. Mandates data governance bodies, establishes 40 action items, and defines maturity assessments for agencies. It highlights cross-agency councils and the need for skills development, data inventories, and metrics.^{OMB M-19-23Federal Data Strategy Action Plan}

Canada’s Directive on Service and Digital. Compels organisations to integrate data lifecycle management, classification, and interoperability into departmental planning. It requires stewardship roles, data quality controls, and privacy-by-design checkpoints.^{Directive on Service and Digital}

Australia’s Data Availability and Transparency Act. Creates the Data Availability and Transparency Scheme (DAT Scheme) regulated by the National Data Commissioner. Data custodians must assess risks, implement project-level controls, and document stewardship decisions.^{Data Availability and Transparency Act 2022}

UK National Data Strategy. Sets missions for unlocking value, building trust, and enabling innovation, calling for stewardship roles across sectors and emphasising public engagement.^{UK National Data Strategy}

New Zealand data leadership audits. The Office of the Auditor-General emphasises clear mandates, cross-agency governance, and data ethics frameworks for stewardship success.^{New Zealand Auditor-General data leadership report}

Core stewardship principles

• Accountability. Assign named data owners and stewards with documented decision rights and escalation paths.
• Transparency. Publish data inventories, governance decisions, and quality metrics to stakeholders.
• Trust and ethics. Embed privacy, security, and ethical impact assessments in data lifecycle decisions.
• Value realisation. Align stewardship outcomes with organisational missions, performance metrics, and service delivery improvements.
• Interoperability. Promote standardised metadata, vocabularies, and APIs to enable reuse across domains.
• Participation. Engage communities, partners, and employees in governance decisions to build legitimacy.

These principles align with OECD recommendations, the European Data Innovation Board’s guidance for data intermediaries, and national strategies across North America, Europe, and Asia-Pacific.

Operating model architecture

Design a layered operating model covering strategic governance, domain execution, and enablement services. At the top, establish a Data Stewardship Council chaired by the CDO or equivalent executive. The council approves policies, investment roadmaps, risk appetites, and stewardship charters. Underneath, domain stewardship forums manage data assets for finance, customer, operations, sustainability, and policy programmes. Enablement teams provide tooling, training, and support for metadata, quality, and access management.

Document decision flows: policy proposals originate from working groups, reviewed by domain forums, escalated to the council for approval, and communicated through change management channels. Align with OMB M-19-23 governance expectations and Canada’s requirement for departmental data committees.

Integrate stewardship into enterprise planning by linking data initiatives to strategic objectives, budget cycles, and performance metrics. Use portfolio management processes to prioritise investments based on regulatory risk, mission value, and readiness.

Funding and resourcing

Secure dedicated funding to sustain stewardship. Establish multi-year budgets covering staffing, tooling, training, and change initiatives. Tie funding requests to statutory obligations—Evidence Act inventories, DAT Scheme accreditation, CSRD assurance—to demonstrate necessity. Use cost allocation models to distribute expenses across business units that benefit from improved data access and compliance.

Develop workforce plans identifying required roles, competencies, and succession pipelines. Leverage existing talent programmes (for example, the U.S. Federal Rotational Program for Data Scientists or Canada’s Digital Community) to fill gaps. Track utilisation and workload to justify additional resources and to prevent burnout.

Where possible, coordinate grant applications or innovation funds (such as the European Commission’s Digital Europe programme) to finance stewardship pilots. Document return on investment through value realisation metrics.

Roles and competencies

Define clear roles:

• Chief Data Officer. Sets vision, chairs the council, liaises with regulators, and ensures integration with enterprise strategy.
• Lead Data Steward. Oversees stewardship programme operations, manages stewards, and reports metrics.
• Domain Data Stewards. Manage data standards, quality rules, metadata, and access requests within assigned domains.
• Data Custodians. Operate systems of record, implement access controls, and ensure technical safeguards.
• Data Owners. Senior business leaders accountable for data value, compliance, and risk decisions.
• Community Representatives. Provide external perspective, particularly for public sector datasets affecting citizens.

Develop competency frameworks covering legal literacy, data management, analytics, facilitation, and change leadership. Align training with Federal Data Strategy action items, Canadian digital talent programmes, and OECD skill recommendations.

Policy framework

Develop policies covering data classification, access management, quality assurance, lifecycle management, sharing agreements, and ethical review. Reference relevant statutes: GDPR for personal data, sector-specific confidentiality rules, and cross-border transfer regulations. Provide templates for data sharing agreements aligned with the Australian DAT Scheme and European Data Innovation Board recommendations.

Establish decision matrices for evaluating data access requests using frameworks such as the Five Safes (safe people, projects, settings, data, outputs). Document criteria, approval authorities, and monitoring requirements. Publish policies internally and, where appropriate, externally to demonstrate transparency.

Ensure policies integrate with enterprise risk management, security, privacy, and procurement frameworks. Conduct annual reviews and update following regulatory changes or audit findings.

Decision frameworks and escalation

Codify decision trees for common stewardship scenarios—data sharing requests, ethical reviews, algorithm approval, emergency data access, and incident response. Each decision tree should reference relevant statutes (for example, GDPR lawful bases, Evidence Act open data requirements, DAT Act safeguards) and specify required artefacts, approvals, and documentation.

Introduce tiered escalation: operational decisions handled within domains, cross-domain issues escalated to the council, and high-risk matters (national security, privacy breaches) routed to executive boards or legal authorities. Maintain an escalation log detailing trigger conditions, participants, decisions, and follow-up actions.

Simulate decision frameworks through tabletop exercises, capturing lessons learned and refining playbooks. Incorporate findings into training to build steward confidence and ensure consistent application.

Core processes

Data inventory and cataloguing. Maintain authoritative inventories with metadata describing purpose, sensitivity, legal basis, steward, owner, retention, and quality indicators. Align with Evidence Act inventory requirements and Canada’s Directive on Service and Digital inventory expectations.

Access request governance. Implement workflows capturing requester identity, legal basis, intended use, and safeguards. Use stewardship review boards to approve or reject requests, documenting reasoning for transparency.

Quality and lifecycle management. Embed ISO 8000-aligned quality controls, retention schedules, archival procedures, and disposal approvals. Stewards should ensure data remains relevant, accurate, and compliant throughout its lifecycle.

Issue management. Provide channels for reporting data issues, track remediation steps, and escalate systemic problems to the council. Align with OMB M-19-23 requirements for risk management and reporting.

Public engagement. Host consultations, publish open data feedback mechanisms, and respond to inquiries as required by Evidence Act Section 3511 and Canada’s open government commitments.

Tooling and platforms

Deploy integrated platforms for metadata management, data cataloguing, access control, quality monitoring, and workflow automation. Ensure tools support audit trails, role-based access, and integration with identity providers. Use dashboards to surface stewardship metrics, data usage analytics, and decision logs.

Implement collaboration spaces for steward communities, capturing playbooks, decision templates, and knowledge articles. Provide APIs for developers to integrate stewardship controls into applications, ensuring consistent enforcement across the enterprise.

Adopt privacy-preserving technologies—such as secure enclaves, differential privacy, and tokenisation—when sharing sensitive data across jurisdictions. Document governance for these technologies to satisfy regulators.

Procurement and partnership alignment

Embed stewardship requirements in procurement templates and partner agreements. Specify data ownership, access rights, quality expectations, audit cooperation, and incident notification duties. Reference Evidence Act open data obligations, GDPR processor clauses, and DAT Scheme safeguards to ensure vendors align with statutory frameworks.

Require suppliers to provide data governance documentation, including steward contacts, metadata standards, and quality assurance processes. Conduct due diligence using questionnaires mapped to OECD and EDIB stewardship principles. Incorporate contract clauses for continuous improvement, metrics reporting, and termination rights if stewardship requirements are breached.

Establish vendor governance forums where stewards and supplier representatives review performance, remediation plans, and upcoming regulatory changes. Share lessons learned to enhance ecosystem-wide stewardship maturity.

Metrics and reporting

Track metrics aligned with legal obligations and organisational goals:

• Inventory coverage. Percentage of data assets catalogued with assigned owners and stewards.
• Access decision cycle time. Average days to approve or reject data access requests.
• Quality compliance. Share of datasets meeting defined quality thresholds and audit outcomes.
• Reuse and value. Number of open datasets published, reuse cases enabled, or revenue/cost savings attributed to stewardship decisions.
• Training completion. Percentage of stewards completing mandatory training modules.
• Risk events. Count of incidents linked to stewardship failures (for example, unauthorised sharing, inaccurate reporting).

Report metrics quarterly to executive committees and annually to regulators or oversight bodies. Publish summaries to promote transparency and accountability.

Maturity model

Assess stewardship maturity using five levels:

• Initial. Informal data management, limited accountability, ad hoc decisions.
• Developing. Emerging governance forums, basic inventories, inconsistent processes.
• Established. Formal councils, documented policies, regular reporting, integrated tooling.
• Managed. Metrics drive continuous improvement, cross-agency collaboration, external transparency.
• Transformative. Stewardship enables innovation, data sharing ecosystems, and community engagement at scale.

Use maturity assessments to prioritise investments, focusing on weakest domains and aligning with regulatory deadlines.

Roadmap

1. Months 0–6: Mobilise. Appoint CDO and stewardship leads, establish council charter, conduct inventory baseline, and identify regulatory priorities. Communicate vision and quick wins.
2. Months 6–12: Build. Roll out policies, launch metadata and access tooling, train stewards, and embed stewardship checkpoints in project lifecycles. Start publishing metrics and open data updates.
3. Months 12–18: Scale. Expand stewardship to partners, integrate with cross-border data sharing programmes, pursue accreditation (for example, DAT Scheme), and conduct independent assurance of governance effectiveness.

Review roadmap quarterly, adjusting for new regulations such as EU Data Act implementing acts, national AI governance policies, or sector-specific mandates.

Culture and change management

Promote a stewardship culture through leadership messaging, recognition programmes, and community-building. Provide learning paths for different roles, including micro-credentials or certifications. Share success stories demonstrating how stewardship improves service delivery, compliance, and innovation.

Engage stakeholders via workshops, open data forums, and citizen advisory panels. Solicit feedback on data priorities, transparency needs, and ethical considerations. Integrate insights into council agendas.

Measure culture shift through surveys, engagement metrics, and participation in stewardship activities. Use results to refine communications and incentives.

Training and capability development

Create tiered curricula tailored to executive sponsors, stewards, custodians, analysts, and project teams. Cover legal foundations (Evidence Act, Privacy Act, DAT Act), policy frameworks, decision processes, and tooling usage. Incorporate scenario-based exercises that simulate access requests, data incident response, and ethical review deliberations.

Partner with learning and development teams to embed stewardship modules into onboarding and leadership programmes. Offer certifications or badges to recognise mastery—aligned with national initiatives such as the U.S. Federal Data Professional training series or Canada’s Digital Academy.

Measure training effectiveness through assessments, performance metrics, and post-course surveys. Track participation to ensure compliance with policy requirements and to identify groups needing additional support.

Case studies

U.S. Department of Commerce. Implemented a data governance board aligning Evidence Act, CIPSEA, and open data mandates. Published a comprehensive data inventory, launched stewardship training, and integrated metadata with grants management systems.

Statistics Canada. Uses the Integrated Metadata and Documentation System (IMDB) to standardise metadata across surveys, enabling transparent stewardship and aligning with the Directive on Service and Digital.

New South Wales Integrated Data Infrastructure. Applies the Five Safes framework and independent ethics review, demonstrating compliance with the Australian DAT Act and building public trust.

UK Local Authorities. Collaborating with the Office for National Statistics Data Campus to develop stewardship playbooks, ensuring local services align with the National Data Strategy.

Transparency and accountability mechanisms

Publish stewardship dashboards highlighting inventory coverage, access decisions, quality metrics, and data sharing outcomes. Provide public-facing documentation for open data assets, including metadata, licensing, and privacy impact summaries. Align transparency reports with statutory requirements such as Evidence Act biennial evaluations and Canada’s open government action plans.

Establish feedback channels—public comment periods, digital service portals, community advisory boards—to gather insights on data priorities and concerns. Document responses and incorporate into stewardship council decisions. Where decisions affect indigenous or vulnerable communities, coordinate with representative bodies to ensure culturally appropriate engagement.

Maintain accountability logs capturing commitments, deadlines, and responsible owners. Share progress with oversight entities, legislatures, or boards to demonstrate responsiveness and build trust.

Assurance and audit

Establish assurance plans covering governance effectiveness, policy compliance, and stewardship outcomes. Coordinate with internal audit to review council operations, data inventory accuracy, and access decision documentation. Use maturity assessments and external benchmarks (OECD, EDIB) to validate progress.

Prepare evidence packages for oversight bodies, including meeting minutes, decision logs, issue registers, training records, and performance dashboards. Document responses to audit findings and track remediation to closure.

Engage external reviewers or peer agencies for independent assessments, especially when participating in cross-border data spaces or national accreditation schemes.

Risk management

Identify risks such as unclear accountability, inadequate resourcing, inconsistent policies, technology fragmentation, and stakeholder mistrust. Map each risk to mitigation actions: role descriptions, funding models, policy harmonisation, platform integration, and engagement strategies. Include stewardship risks in enterprise risk registers and board reports.

Develop KRIs—council attendance, overdue policy reviews, unresolved data access complaints, or declines in data quality metrics. Establish escalation thresholds and response plans.

Align with national risk frameworks, such as Canada’s Integrated Risk Management Policy or Australia’s Commonwealth Risk Management Policy, ensuring stewardship risks receive appropriate oversight.

Future outlook

Monitor the European Data Innovation Board’s forthcoming guidance on data intermediation services, the EU’s Data Act delegated acts on smart contracts, and national AI governance frameworks such as U.S. OMB M-24-10. Anticipate increased scrutiny on algorithmic accountability, requiring stewards to document dataset provenance and model governance.

Track international collaborations like the Global Partnership on AI (GPAI) and Digital Nations, which share stewardship best practices and may set expectations for interoperable governance. Engage in these forums to influence standards and adopt proven approaches.

Invest in emerging capabilities—privacy-enhancing technologies, data clean rooms, responsible AI toolkits—that will become core to stewardship as regulations evolve. Document pilots, outcomes, and risk assessments to maintain transparency.

Appendix: stewardship artefacts

• Stewardship charter. Defines mandate, membership, decision rights, and reporting lines.
• Data policy library. Collection of approved policies with review dates and owners.
• Access decision log. Records requests, approvals, denials, and rationale.
• Training catalogue. Lists mandatory and elective courses with completion tracking.
• Stakeholder engagement plan. Outlines consultation methods, feedback loops, and communication cadence.

Maintain artefacts in a secure repository with role-based access and version history, ensuring availability for auditors, oversight bodies, and programme teams.