FSA SII progress review findings – More Data Governance required

February 2011 – UK Financial Services Authority publishes findings of their Solvency II Internal Model Approval Process (IMAP) thematic review. 

Worryingly, but not surprising are the findings that data management, data quality and data governance are areas requiring most attention: I include specific paragraphs below:

3.2 Data management appeared to be one area where firms still have comparatively more to do to achieve the likely Solvency II requirements.

3.15 Data quality: Few firms provided sufficient evidence to show that data used in their internal model was accurate, complete and appropriate.

6.10 We witnessed little challenge or discussion on data quality at board level. We expect issues and reporting on data governance to find a regular place within board and committee discussions. Firms need to ensure that adequate and up-to-date quality management information is produced. It is important that the board has the necessary skills to ask probing questions.

See the full report at:

http://www.fsa.gov.uk/pubs/international/imap_final.pdf

Know your data

You must know your data.

Do you know what’s in your data box of chocolates?

You must know where it is, what it should contain and what it actually contains.

When your data does not contain what it should, you must have a process for correcting it.

CEOs, CFOs and CROs often take the above as “given”.  They make business critical decisions using information derived from data within their organisation.  After all, its applied common sense.

For the insurance industry, Solvency II requires evidence that you are applying common sense.

If you operate in the EU market or process the personal data of EU data subjects, you must comply with the EU General Data Protection Regulation (GDPR) or face severe fines. To comply, you must “know your (personal) data” and how you manage it.

In my experience, data is like a box of chocolates “You never know what you’re gonna get.”

Do you know your data?