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Altair – Data is the foundation for board assurance

Should data management be a performance standard in its own right? asks Darren Smith.

For any modern organisation, data should be your core asset, a foundation that drives and informs strategic decisions and efficiencies. Utilising data to shape and enhance operational and customer performance through digital transformation may be where the housing sector is moving, but organisations need firstly to ensure that there is a minimum standard in place that provides the firm foundation and framework before you can move along the data utilisation spectrum.

As registered social landlords become increasingly data intensive and their reliance on data grows, we ask the question, should your organisation be approaching the management and governance of data as if it were a performance standard in its own right?

The regulator states that a robust evidence based, challenging self-evaluation is a key element of the Regulatory Framework. It is the primary source of evidence for the compliance statement demonstrating the performance standards are being met.

The recent announcements from the housing minister rising to the challenge of decarbonisation, both with future homes and existing ones, and the five-year rent policy that provides certainty and also flexibility for individual RSLs to set affordable rents, both demand accurate and extensive data. Many RSLs are reviewing their stock condition data and Altair’s recent work on affordable rent models for Community Housing Cymru demonstrates the need to access and accumulate accurate data. Ensuring that the data is accurate in the first place is key for making assumptions and designing solutions.

The consequences of getting data governance wrong could be:

  • A downgrade in judgement status – Recent regulatory interventions have highlighted the detrimental consequences of not challenging and scrutinising data by boards which has resulted in increased intervention on an individual organisation level and  a sector wide focus on assurance. Poor data and inaccuracies seem indicative of a poor organisation-wide internal control framework.
  • Breeching GDPR –With General Data Protection Regulation (GDPR) in place for over a year its principles should be weaved into your organisation’s data protection procedures. While we have yet to see any high-profile penalties within the sector, data breaches are on the rise, with the Information Commissioner’s Office reporting a 15 per cent increase in data breaches involving housing associations in recent months. As well as the financial penalties, breaching data protection will significantly worsen your landlord – tenant relationships.
  • Incomplete data on your assets – With the Grenfell tragedy shaking up building regulation, it is your responsibility as a landlord to know about all components of your properties to protect the welfare of your tenants and keep them safe. At the heart of this is having complete, accurate and up to date data on all your assets.

So, if data were to be a performance standard, what might it look like?

Management of data is first and foremost a governance issue. By ensuring you have the suitable arrangements in place, you can then embed them throughout your organisation while providing assurance to your board all areas are covered. The key elements of a good data governance framework should start with:

  • Internal data governance policy – A document that sets out the data principles and arrangements in place to achieve effective data management. This document should act as an overarching reference where other strategies and policies cite their own data procedures and ensures consistency at all areas and all levels.
  • Data hierarchy and framework – Who is ultimately responsible for holding data within your organisation? Who is the chief data officer and delegated data stewards, and do you have clear lines of accountability? In addition, each process should have a bespoke procedure outlining timelines, accountability, processes and check points – flow diagrams are a great way to visualise this.
  • Independent view – Processes either need to be scrutinised by an external independent view or an internal view from someone who should be separate from that specific data process.
  • Embed throughout – Data governance needs to be embedded into your organisation’s culture, with staff members kept up to date with data legislation and frequent data handling training.

In a world where decisions are heavily reliant on having the correct data, organisations should be fully aware of the risks and consequences of poor data; this is no different from any other risk and should be treated the same way.

You already have a robust risk management framework – just apply it to your data.

Darren Smith is an analyst at Altair darren.smith@altairltd.co.uk

Altair and Devonshires 2020 leadership and strategic event – 28 January 2020 – Wales Millennium Centre

2020 requires a clearer vision from the sector than ever before as you plan to meet the challenges of decarbonisation whilst meeting the demand for more homes and expectations from tenants and residents. Our theme this year will focus on sustainability, we ask  ‘how can RSLs position themselves to meet the costs of sustainable housing? We will explore the financial trade-offs, the culture and leadership required, value for money and  tenants and residents engagement.

This event is equally relevant to CEOs, Chairs and members of your Executive team. The cost of the event is £100+VAT per person.

If you haven’t already booked, just send your full details to seminars@devonshires.co.uk or call on 020 7065 1871

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