Copy Data Management (CDM) Governance Checklist

Effective copy data management (CDM) is critical for ensuring organizational data integrity, security, and compliance. With growing data complexities and diverse use cases, establishing a well-structured governance framework is more important than ever. This checklist provides a comprehensive guide to building a strong CDM governance practice, from defining roles and responsibilities to identifying compliance standards and risk mitigation strategies. Let’s dive into the 8 essential steps to streamline your CDM approach and optimize data use while minimizing risks:

1. Identify and Define Governance Body
   • Define the purpose and business value of the body
   • Define artifacts – existing and new – for which the governing body will be responsible
   • Frequency of meeting and updating governance policies
   • Process for adding new data uses and types
   • Budgetary and cost oversight roles, as applicable
   • Define record-keeping requirements
2. Define Types of Copies and Uses
   • Disaster recovery/backups
   • Generative AI
   • Data analytics
   • Development and testing scenarios
   • Regulatory requirements
3. Define Roles with CDM Capabilities
   • Creating copies
   • Reporting on copies
   • Archiving and deleting copies
   • Training requirements for each role
   • Employment status for each role (FTE, contractor, temp, etc.)
4. Define and Outline Governing Bodies and Data Requirements
   • HIPAA – specific to healthcare providers
   • GDPR – specific to data about EU citizens
   • CCPA – specific to data about California residents
   • PCI DSS – specific to credit-card processing data, including credit card numbers, cardholder names
   • NIST 800-53 and ISO 27001
   • Organization-specific rules
5. Identify and Define Masking Tools
   • Document and describe purposes for masking
   • Document fields to be masked
   • Define testing parameters to ensure data is masked
6. Define Risk-mitigation Practices
   • Identify internal teams to coordinate with, to ensure risk mitigation
   • Create risk register
7. Define Retention Policies
   • Where data is retained
   • Who is responsible for retaining data sets
8. Define Retirement Policies
   • Methodology for retiring
   • Who is responsible for retiring data sets

For more information on copy data management, see Copy Data Management: The Challenges, Benefits and How Silk Simplifies the Process.