. 10

Recognizing the importance of data to BFD as an essential asset to underpin decision-making, and in line with the Data Privacy for Action by Everyone, Everywhere with Insight, Impact, and Integrity, BFD is committed to the development of a data governance policy under the action plan of the Digital Transformation Strategy (2024-2029).

The policy will govern the ways in which BFD uses, processes, and disseminates data, including operational and administrative data.

The principles guiding the policy are as follows: it should be people-centered to generate benefits for the targeted people and BFD improvement through data use, and do no harm; all data should be systematically assessed for quality and integrity; data should be findable, accessible, interoperable, and reusable, and ensure accountability and transparency; data management should be proportional and minimally burdensome; and BFD should promote a data-driven culture of decision-making.

This document describes the data governance structure at strategic, tactical, and operational levels for the optimal organization and use of data in BFD. The document also covers risks and mitigation measures related to the policy and provides high-level guidance on the implementation monitoring and evaluation of the policy.

Reliable, timely, and granular data is essential to support the achievement of BFD’s strategic objectives and to monitor progress, identifying areas of success and those that require further attention. As BFD addresses global challenges such as climate change, food system disruptions, and crises in fragile environments, timely and accurate data becomes critical in enabling informed decision-making, risk management, and crisis response planning. Furthermore, data plays a pivotal role in long-term strategic planning and operational management, ensuring that BFD can navigate the complexities of the global humanitarian and development landscape effectively. BFD seeks to adopt a data-driven organizational culture that leverages the data ecosystem while ensuring that all data governance practices align with global standards.

BFD’s operations rely on a diverse set of data, including project-level data, indicators, and operational, administrative, and financial data. These data points are critical for ensuring transparency, accountability to donors, effective project design, implementation support, and robust monitoring and reporting. Data management at BFD is categorized into three main types:

·        Administrative Data: This includes corporate financial data (contracts, general ledger, commitments, financial reporting), human resources data (workforce management, payroll, performance tracking), board and executive management data (strategic reports, governance decisions, board meeting minutes), and data from supportive units and departments (e.g., IT, procurement, logistics, MEAL, and communications,). Administrative data enables smooth internal operations and governance. Due to the sensitive nature of certain data, particularly from board and executive management, elevated security measures are applied.

·        Operational Data: This category encompasses data related to the execution of BFD’s core activities, including project management data such as grant agreements, project finance tracking, implementation and supervision reports, results reporting to governing bodies, impact assessments, and program performance indicators. Operational data plays a pivotal role in tracking the progress and impact of BFD’s projects, supporting decision-making, and fulfilling reporting requirements to stakeholders and donors.

·        Supportive Data: Supportive units, such as IT, procurement, logistics, and communications, generate data critical for the operational efficiency of BFD. This data includes IT infrastructure management, vendor and procurement records, logistics and supply chain tracking, legal compliance documentation, and internal and external communications data. While categorized under administrative data, it supports BFD’s operational framework and strategic initiatives.

BFD’s core data management systems securely integrate operational and administrative data, providing accessible dashboards and interfaces to support internal and external users. However, certain datasets, such as impact assessments and supplementary fund activities, are not yet fully integrated into central systems and are maintained in silos. Addressing these gaps is a priority for BFD’s digital transformation strategy.

As part of BFD's commitment to transparency and accountability, extensive project information is made available through online platforms, including the International Aid Transparency Initiative (IATI), Cluster DHIS, and Reporting platforms. In 2024, BFD further strengthened its commitment to data governance through the approval of its Digital Transformation Strategy (2025-2029). This strategy underscores the critical role of data in operational effectiveness, external reporting, and compliance with global data standards.

The Data Governance Policy is a cornerstone of BFD's Digital Transformation Strategy and provides a framework to ensure that data is managed as a strategic asset throughout its lifecycle from collection and storage to processing, analysis, dissemination, and disposal. Key benefits of the policy include:

1)        Efficient and timely use of high-quality data to support data-driven and evidence-based decision-making, enabling impactful project design and implementation.

2)        Ensuring data interoperability, consistency, and accessibility across datasets to facilitate smooth internal operations and external reporting.

3)        Promoting standardization and harmonization of data content, improving metadata documentation, and enhancing data quality and accuracy.

4)        Reducing risk exposure by managing the increasing reliance on external and public data sources in alignment with BFD’s Enterprise Risk Management Policy.

5)        Enhancing the value of data as a strategic asset, which directly contributes to BFD’s mission and its impact on response to the communities.

This Data Governance Policy outlines how BFD manages data generation, usage, processing, and dissemination, providing guiding principles for data engagement across the organization. It applies to all BFD employees and encompasses all aspects of data management, including operational and administrative data in various formats like documents, reports, audio, video, and multimedia content. Accountability for data management is based on the control level BFD personnel have over the data, whether it's internally produced or obtained from external partners. Sensitive personal data, including personally identifiable information, is included within this policy's scope and is governed by BFD’s Data Protection Policy, ensuring that data protection and privacy are integrated into all facets of BFD’s data governance.

Data is central to BFD’s work and is a critical asset in supporting decision-making processes, operational efficiency, and transparency. The Data Governance Policy emphasizes the value of all operational and administrative data that BFD generates and processes, ensuring that it is managed securely and efficiently while upholding the principle of doing no harm to any data subject[1]. The objectives of this policy are as follows:

Figure 1: Data Governance Policy Objective

The purpose of the BFD Data Governance Policy is to establish a comprehensive framework for the responsible and strategic management of data across the organization. This policy aims to ensure that data is treated as a valuable asset that supports decision-making, operational effectiveness, transparency, and accountability, in alignment with BFD's Digital Transformation Strategy (2025-2029) and its broader mission.

This policy serves as a guide for BFD staff, contractors, and consultants, outlining their roles and responsibilities in the collection, storage, management, sharing, and disposal of data in compliance with applicable regulations and internal policies. It also provides clear processes for safeguarding data integrity, security, and privacy, while ensuring that data management practices foster collaboration and innovation across all departments.

The policy’s specific purposes are to:

•     Define clear roles and responsibilities for managing various types of data, establishing accountability at every stage of the data lifecycle.
•     Develop best practices for effective data management and protection, ensuring that BFD's data assets are secure, accurate, and accessible to authorized personnel.
•     Protect BFD’s data from security risks and ensure compliance with relevant data protection laws, including GDPR and other regulations.
•     Support data-driven decision-making and enhance operational efficiency by ensuring that high-quality data is available in a timely and accessible manner.
•     Promote transparency and accountability by ensuring that data is collected, processed, and shared in line with BFD’s policies on privacy, data protection, and public disclosure.
•    Encourage a culture of continuous improvement in data governance, leveraging technological advancements to modernize and streamline data management processes, while aligning with BFD’s resources and operational needs.

This policy applies to all data owned, collected, or processed by BFD across its departments, units, and projects. The policy covers:

Figure 2: Policy Scope

The policy sets out a number of guiding principles for data governance. The guiding principles cover risk mitigation and good practice principles for data use within the global landscape. All of BFD’s engagement with data will strive to produce outcomes centering on the well-being of people and community, doing no harm to any individuals or entities. The guiding principles apply solely to BFD and to all data managed and processed by BFD, once entered into BFD data systems and repositories.

The following framework outlines the principles and minimum standards that guide BFD’s data governance procedures[2] and must be adhered to by all BFD staff.

Figure 3: Data Policy Framework

6.1           Governance and Ownership

Institutional data is owned by BFD, not by any individuals. The departments and BFD units may have delegated responsibility for some datasets. Data Stewards have the ultimate responsibility to manage the data within their authority in compliance with the law and BFD policies.

All users of data have responsibility for preserving the security and integrity of BFD data. All data users must:

•           Observe any ethical restrictions applied to the data.

•           Adhere to policies or procedures that apply to the data.

•           Ensure the quality of data and any analysis results they provide are accurate and interpreted correctly, free of bias.

•           Have proper access controls in place. Any breaches of access controls where personal data are shared inappropriately need to be reported as defined in the data breach management procedure.

Table 1: Data Governance and Ownership Matrix

Data Governance Role	Data Governance Responsibility
Data Governance Committee	The Data Governance Committee is responsible for overseeing the implementation of the Data Governance Policy across BFD. Responsibilities include establishing and enforcing data governance policies, approving strategic initiatives related to data management, overseeing risk management, monitoring compliance, reviewing audit reports, promoting a culture of data-driven decision-making, and conducting periodic policy reviews.
Data Protection Officer	The Data Protection Officer ensures that BFD’s data practices comply with data protection regulations such as GDPR. Responsibilities include monitoring compliance with data protection laws and policies, conducting Data Protection Impact Assessments (DPIAs), serving as the primary contact for data subjects regarding their rights, managing incident response procedures for data breaches, and providing training and guidance on data privacy and protection practices.
Departmental Data Stewards	Departmental Data Stewards are responsible for managing data within their departments to ensure accuracy, accessibility, and security. Their responsibilities include overseeing data collection, processing, and storage; monitoring access to departmental data; addressing data-related issues; ensuring compliance with internal policies and external regulations; and providing regular reports on data governance compliance to the Data Governance Committee.
IT, DT, and AI Unit	The IT and Digital Transformation Unit is responsible for implementing and maintaining the technical infrastructure that supports data governance at BFD. Responsibilities include implementing and maintaining encryption, access controls, and secure storage; managing cloud services, databases, and digital platforms; monitoring and responding to data security threats; ensuring regular backups and disaster recovery plans are in place; and supporting Data Stewards and the DPO in resolving technical data issues.
All BFD Staff	All BFD staff are responsible for adhering to data governance practices and managing data according to the principles outlined in the policy. Responsibilities include following the Data Governance Policy when collecting, processing, or sharing data; reporting any data incidents or security concerns; ensuring personal and sensitive data is handled with care; participating in training sessions on data governance, security, and privacy; and using data responsibly while maintaining accuracy and compliance with all policies and regulations.

 

6.2           Principles of Data Governance

6.2.1        Integrity and quality

All BFD data will be systematically assessed for quality along the dimensions of relevance, accuracy, credibility, timeliness, accessibility, interpretability, and coherence. The quality of BFD data depends on the quality of data created within the organization, and the quality of internal processes for the collection, validation, storage, processing, analysis, and dissemination of data and metadata. The necessary standards, in line with international standards as well as roles and responsibilities, will need to be in place to ensure data quality and the integrity of data systems used by BFD[3].

6.2.2        Accountability and transparency

Specific data management roles will be defined to ensure accountability and transparency; to systematically assess data quality; to be answerable for issues that may arise concerning data; to accurately report what data BFD has, how it is being used, and where it is stored or shared; and to ensure that data is being used with integrity, lawfully, fairly and traceably, and for valid purposes. BFD will strive to make its data findable, accessible, interoperable, and reusable in line with the Findable, Accessible, Interoperable, and Reusable (FAIR) Data Principles:

(i)    Findable: data will be well described with rich metadata and the same metadata will be indexed and registered in a searchable source, in line with best practice, to facilitate the process of finding data.

(ii)  Accessible: data will be accessible such that it can be obtained by users with the appropriate level of authentication and authorization.

(iii) Interoperable: data needs to interoperate with applications or workflows for analysis, storage, processing, preservation, and dissemination.

(iv) Reusable: to achieve the reuse of data, metadata, and data will be well described so that they can be replicated and/or combined with other data.

6.2.3        Proportionality

Collecting and analyzing data is costly for the projects and all BFD sections and branches. Collecting or accessing and collating datasets, and processing them, will be carried out in the least burdensome ways possible to minimize fatigue and unnecessary costs for BFD. Such methods include the use of efficient and proportional data management methods across various departments, programs and units to ensure that only the necessary information is collected or accessed and processed, leveraging technology and alternative data sources such as administrative data, geographic information system (GIS) data, or big data. Proportionality will be applied to minimize the amount of storage space and services to secure the data. Similarly, reporting of analytics and statistics needs to be measured to ensure that it focuses only on relevant aspects and is as concise as possible.

6.2.4        Data Security and Privacy

Protecting sensitive and personal data is of paramount importance to BFD. The organization is committed to implementing comprehensive data security and privacy measures to safeguard data against unauthorized access, breaches, and misuse.

6.2.4.1         Data Security Measures

Access to data is controlled through Role-Based Access Control, ensuring that individuals have access only to the data necessary for their roles. Multi-Factor Authentication MFA is employed for critical systems to enhance security. Regular reviews and updates of user access rights are conducted to maintain appropriate access levels.

Encryption is utilized to protect data both at rest and in transit. Sensitive data stored on servers and devices is encrypted using industry-standard protocols. Secure communication protocols like SSL/TLS are used for data transmission to prevent interception.

Network security is maintained through the deployment of firewalls and intrusion detection/prevention systems. Systems and software are regularly updated and patched to address vulnerabilities. Endpoint security measures include installing antivirus and anti-malware solutions on all devices and enforcing security policies for mobile and remote devices.

6.2.4.2         Data Privacy Protocols

All personal data processing activities must have a lawful basis, such as consent or contractual necessity. Consent management practices ensure that explicit consent is obtained where required, with records maintained and mechanisms in place for easy withdrawal of consent.

Procedures are established to uphold data subject rights, including requests for access, rectification, erasure, and restriction of processing. Data Protection Impact Assessments are conducted for high-risk data processing activities to identify and mitigate potential privacy risks.

6.2.4.3         Incident Response Plan

A structured incident response plan is in place to address data breaches promptly. Upon suspicion of a breach, staff must notify the Data Protection Officer immediately. Steps are taken to contain the breach, assess its impact, and determine the affected data subjects. Regulatory authorities and affected individuals are notified within 72 hours if required by law.

6.2.4.4         Training and Awareness

Regular training programs are conducted to educate staff on data security practices and policies. Training includes awareness of phishing threats, safe handling of personal data, and compliance with data protection regulations.

6.2.4.5         Responsibilities

The IT Unit is responsible for implementing and maintaining technical security measures. The Data Protection Officer oversees privacy compliance and manages responses to data breaches. All staff members are required to follow security protocols diligently and report any incidents or concerns.

6.2.5        Compliance and Auditing

Ensuring compliance with the Data Governance Policy and relevant legal requirements is crucial for maintaining the integrity and reputation of BFD. A structured compliance and auditing framework is established to monitor adherence to policies, identify areas for improvement, and ensure corrective actions are taken when necessary.

6.2.5.1         Compliance Monitoring

Regular audits are conducted to assess compliance with data governance policies, data protection laws such as the GDPR, and industry best practices. Internal audits are performed annually, while external audits occur every two years or as required. The Internal Audit Team, under the oversight of the Data Governance Committee, is responsible for planning and executing these audits.

6.2.5.2         Audit Processes

The audit process involves defining clear objectives, scope, and methodologies. Evidence is collected through interviews, system inspections, and review of documentation. Findings are documented in comprehensive reports that detail compliance status, identified issues, and recommendations for corrective actions. Follow-up activities ensure that corrective measures are implemented effectively.

6.2.5.3         Compliance Reporting

Departments are required to submit quarterly compliance reports to the Data Governance Committee. These reports include updates on adherence to policies, any compliance issues encountered, and steps taken to address them. Immediate reporting of any data breaches or significant compliance issues to the Data Protection Officer and the Data Governance Committee is mandatory.

6.2.5.4         Corrective Actions

In cases of non-compliance, a thorough investigation is conducted to identify the root cause. A remediation plan is developed and implemented promptly. The effectiveness of corrective actions is monitored to prevent recurrence of the issues.

6.2.5.5         Responsibilities

The Data Governance Committee oversees compliance efforts and ensures that policies remain current and effective. The Data Protection Officer monitors compliance with data protection laws and handles data subject requests. The Internal Audit Team conducts audits and reports findings to the relevant stakeholders. All staff members are responsible for adhering to policies and reporting any compliance concerns.

6.3           Classification and Security

To ensure the appropriate protection of BFD's data assets, all data within the organization must be classified according to its sensitivity and importance. This classification determines the level of security controls required for each type of data and guides staff on how to handle and protect it.

BFD has established the following data classification levels:

1. Highly Confidential (High Security): This category includes data that requires the highest level of protection due to legal, regulatory, contractual, or policy requirements. Unauthorized disclosure or loss of this data could cause significant harm to individuals or the organization. Examples of highly confidential data include personal information of beneficiaries and employees (such as health records and social security numbers), financial records, authentication data, and legal documents.
2. Confidential (Medium Security): Data in this category is not intended for public disclosure and could harm BFD if improperly disclosed. This includes internal communications, non-public emails, budget plans, internal reports, and non-public agreements.
3. Public (Low Security): This category encompasses data intended for public disclosure, posing minimal risk if shared. Examples include marketing materials, press releases, published reports, and information available on BFD's public website.

6.3.1        Data Handling Guidelines:

• Access Controls: Access to data is granted based on its classification level. Highly confidential data is restricted to authorized personnel only, requiring multi-factor authentication and regular reviews of access rights. Confidential data access is granted based on job roles, protected by strong passwords and periodic access reviews. Public data is accessible to all staff and the public as appropriate.[4]
• Storage and Encryption: Highly confidential data must be stored in encrypted form, both at rest and in transit, using secure servers and industry-standard encryption protocols. Confidential data should be stored securely with appropriate encryption during transmission and on secure servers with access controls. Public data does not require special storage measures but should be protected from unauthorized alteration.
• Transmission: When transmitting highly confidential data, secure channels such as SSL/TLS must be used, and emails or file transfers must be encrypted. Confidential data should be transmitted using secure methods, avoiding unsecured channels. Public data can be transmitted openly but must ensure accuracy and integrity.
• Disposal: All data types must be disposed of securely. Electronic data should be erased using certified data wiping tools or physical destruction of storage media. Physical documents should be shredded or incinerated to prevent unauthorized access.

6.3.2        Responsibilities

Data Stewards are responsible for ensuring that data within their departments and units is correctly classified and handled according to these guidelines. All staff must be aware of the data classification levels and handle data appropriately. Detailed procedures and examples can be found in the Data Classification Standard and Data Handling Guideline documents.[5]

6.4           Data Lifecycle Management

Effective management of data throughout its lifecycle is essential for maintaining data integrity, security, and compliance. BFD recognizes the importance of handling data appropriately from its creation to its eventual disposal. The data lifecycle encompasses the following stages:

6.4.1        Data Collection

Data should be collected only for specified, explicit, and legitimate purposes. Collection methods must comply with legal requirements, and where necessary, informed consent must be obtained from data subjects. Data minimization principles apply, ensuring that only necessary data is collected.

6.4.2        Data Storage

All data must be stored securely, consistent with its classification level. Appropriate access controls and encryption measures must be in place to protect data from unauthorized access or loss. Regular backups should be performed in line with BFD's backup policy to prevent data loss due to system failures or other incidents.

6.4.3        Data Processing

Processing of data must align with the purposes for which it was collected. Data accuracy and integrity must be maintained during processing activities. Records of processing activities should be maintained as required by regulatory obligations.

6.4.4        Data Sharing and Dissemination

Data may only be shared internally and externally with authorized parties. When sharing data with third parties, Data Sharing Agreements or Non-Disclosure Agreements must be established to ensure data protection obligations are met. Personal data should be anonymized or pseudonymized when appropriate to protect individual privacy.

6.4.5        Data Archiving

Data that is no longer actively used but must be retained for legal, historical, or compliance reasons should be archived securely. Archived data must be stored with appropriate security controls and access restrictions. Periodic reviews of archived data should be conducted to determine if continued retention is necessary.

6.4.6        Data Disposal

When data is no longer required, it must be disposed of securely. Electronic data should be erased using certified data wiping tools or by physically destroying storage media. Physical documents containing sensitive information must be shredded, pulped, or incinerated. All disposal activities should be documented for audit purposes.

6.4.7        Data Retention Periods

Retention periods for different types of data are established in accordance with legal, regulatory, and operational requirements. For example, personal data should be retained only as long as necessary to fulfill the purpose of its collection and any additional period required by law. Financial records may need to be retained for at least seven years to comply with financial regulations.[6]

6.4.8        Backup Procedures

Regular backups are essential to prevent data loss. Backups must be encrypted and stored securely, preferably off-site or in a secure cloud environment. Backup restoration processes should be tested regularly to ensure data can be recovered effectively in the event of a loss.

6.4.9        Secure Disposal Methods

Secure disposal methods must be employed to ensure that data cannot be reconstructed or retrieved after disposal. For electronic data, certified data wiping tools or physical destruction methods should be used. Physical documents should be destroyed using shredding or incineration.

6.4.10   Responsibilities

Data Stewards oversee the lifecycle management of data within their departments, ensuring compliance with these guidelines. The IT, DT, A IUnit provides the necessary tools and support for secure data management. All staff members must adhere to the data lifecycle procedures relevant to their roles.

6.5           Training and Capacity Building

BFD is dedicated to fostering a culture of data awareness and compliance through continuous training and capacity-building initiatives. Training programs are designed to equip staff with the knowledge and skills necessary to manage data responsibly and securely.

6.5.1        Training Programs

• General Data Governance Training: All staff members receive training on the organization's data governance policies, data handling best practices, and security awareness. This training occurs during onboarding and is refreshed annually.
• Role-Specific Training: Data Stewards, IT, DT, AI staff, and managers receive specialized training tailored to their specific responsibilities. This includes technical training on data management tools, understanding compliance requirements, and best practices for data governance. Training is provided upon assignment to the role and updated as needed.
• Data Protection and Privacy Training: Staff members who handle personal data receive training on GDPR compliance, data subject rights, and consent management procedures. This training is conducted semi-annually to ensure ongoing compliance with data protection laws.

6.5.2        Training Implementation

The HR and IT, DT, AI Unit, in collaboration with the Data Governance Committee, are responsible for delivering these training programs. A variety of methods are employed, including workshops, e-learning modules, and webinars. Assessments are conducted to measure understanding and effectiveness, ensuring that training objectives are met.

6.5.3        Capacity Building

BFD provides resources and access to tools and technologies that support effective data governance. Continuous learning is encouraged, with staff supported in staying updated on the latest trends and best practices in data governance and data protection.

6.6           Third-Party Data Handling

When engaging third-party service providers or partners who have access to BFD's data, strict guidelines are in place to ensure the protection and proper handling of information.

6.6.1        Data Processing Agreements (DPAs)

All third parties processing personal data on behalf of BFD are required to enter into a Data Processing Agreement. The DPA outlines the scope, purpose, and duration of data processing activities, as well as data security measures and compliance obligations. It ensures that third parties adhere to the same data protection standards as BFD.

6.6.2        Due Diligence

Prior to engaging third parties, BFD conducts due diligence assessments to evaluate their data protection policies and security measures. Regular audits and compliance checks are performed to monitor ongoing adherence to BFD's data governance requirements.

6.6.3        Data Sharing Guidelines

Data shared with third parties is limited to the minimum necessary to perform the contracted functions. Appropriate data security measures must be implemented by the third party to protect the data. In the event of a data breach or incident, third parties are required to notify BFD immediately.

6.6.4        Termination Procedures

Upon termination of the contractual relationship, third parties must return or securely delete all BFD data in their possession. Written certification confirming data deletion is required to ensure compliance.

6.6.5        Responsibilities

Contract Managers are responsible for ensuring that DPAs are in place and that third parties comply with data governance requirements. The Data Protection Officer provides guidance on third-party data handling and monitors compliance. All staff involved in engaging third parties must follow these guidelines to protect BFD's data assets.

Implementing the policy will create the conditions for data to be more interoperable and findable. The policy will guide BFD processes to enhance the quality and accuracy of data and to make more data available online and through other channels, so as to increase the use and visibility of BFD data.

1.        Implementation will require investments in systems capacity like DHIS, ERP Next, including upgrading IT infrastructure, human resources upskilling, recruitment of new roles in the longer term, and development of various frameworks, in line with international data standards.

2.        An action plan will be prepared by IT, DT, AI unit, and Data Governance Committee to implement the policy and will support action-oriented knowledge and capacity development to ensure adoption at all levels of BFD. The action plan will specify activities to be carried out by various branches, departments, and units and will be phased and aligned with each replenishment period. The plan will be consistent with BFD’s Digital Transformation Strategy Action Plan 2024-2029 and will be sufficiently practical and tactical to ensure operational and organizational efficiency and impact. The action plan will identify the resources needed and timelines for various key task areas.

To ensure the ongoing effectiveness of the Data Governance Policy, BFD has established mechanisms for reporting, monitoring, and assessment.

8.1           Regular Reporting

Departments are required to submit quarterly reports on compliance with the policy and progress toward KPIs. These reports enable the Data Governance Committee to monitor implementation and address any issues promptly.

8.2           Policy Review

A midterm review of the policy will be conducted six months after implementation to assess its effectiveness and make necessary adjustments. A comprehensive policy review will occur every two years or as needed, considering changes in regulations, technology, and organizational needs.

8.3           Continuous Improvement

Feedback from staff, audit results, and performance metrics are used to identify areas for improvement. The policy and associated procedures are updated accordingly to enhance data governance practices continually.

Managing risks related to data governance is essential for safeguarding BFD's data assets and maintaining the trust of stakeholders. A comprehensive risk management framework has been established to identify, assess, mitigate, and monitor risks associated with data security, privacy, compliance, and operations.

9.1           Risk Identification and Assessment

Regular risk assessments are conducted at both the departmental and organizational levels to identify potential threats. Risks are evaluated based on their likelihood and potential impact, allowing for prioritization and focused mitigation efforts.

9.2           Risk Mitigation Strategies

Data Security Risks: Technical controls such as encryption, access controls, and robust network security measures are implemented to protect data from unauthorized access and breaches.

Data Privacy Risks: Compliance with GDPR and other data protection laws is strictly maintained. Consent is managed appropriately, and data subject rights are protected.

Operational Risks: Business continuity is supported through regular backups, disaster recovery plans, and procedures to ensure ongoing operations in the face of disruptions.

Compliance Risks: Regular audits and monitoring activities ensure adherence to legal requirements and internal policies.

Reputational Risks: Transparency, ethical practices, and effective communication are upheld to maintain stakeholder trust and organizational reputation.

9.3           Risk Monitoring

Continuous monitoring of risk indicators and the effectiveness of control measures is conducted using automated tools and real-time alerts. This proactive approach enables the early detection of potential issues and timely responses.

9.4           Incident Management

An incident response team and plan are in place to address any data-related incidents. Incidents are documented and analyzed to identify root causes and implement measures to prevent recurrence.

9.5           Responsibilities

The Data Governance Committee oversees the risk management process, ensuring that risks are managed effectively across the organization. The Data Protection Officer manages data privacy risks and ensures compliance with data protection regulations. The IT, DT, and AI Unit addresses technical risks and implements necessary security controls. All staff members are responsible for reporting risks and adhering to mitigation procedures.

10.1     Definitions

Big data	Datasets generated by business transactions, social media, phone logs, communication devices, web scraping and sensors that are too large or complex to be dealt with by traditional data-processing application software.
Data access	The means and conditions under which data can be viewed or used. A access also refers to terms, copyright issues and confidentiality constraints related to how the data can be used.
Data analysis	The process of transforming raw data into usable information, often presented in the form of a published analytical article, in order to add value to the statistical output (UN data Glossary).
Data dissemination	The distribution or transmitting of data to end users, in this context in common open formats via the BFD website using internet protocols.
Data governance	The set of rules, policies and procedures for managing data throughout its life cycle, from collection to dissemination, to ensure data quality, reliability, compliance and security.
Data interoperability	A feature in a set of data that allows the data to be connected or merged with other compatible data and facilitates sharing or exchange of data as well as processing across multiple data systems.
Data processing	The operation performed on data in order to derive new information according to a given set of rules (UN Data Glossary).
Data quality	The degree of completeness, correctness (accuracy), timeliness and availability of data. (UN data Glossary)
Data steward	The role concerned with ensuring the fitness for purpose and the correct usage of data.
Data subject	Any individual person who can be identified, directly or indirectly, via an identifier
Data user	Recipient of statistical information, who transforms it into knowledge needed for decision-making or research. (UNdata Glossary)
Data-driven culture	The principle established in the process of social practice that requires all staff and decision makers to focus on the information conveyed by the existing data, and make decisions and changes according to these results, rather than on the basis of experience in a particular field.
Financial data	Facts and figures on loans, disbursements, grants, cofinancing, debt, interest rates, repayments, payment periods, borrowing, credit ratings and rates of return on investments.
Metadata management	The overarching process that applies to the management of metadata.