20 FAM 202
DATA AND AI GOVERNANCE CONSTRUCT AND COMMITTEES
20 FAM 202.1
Data Governance Framework
(CT:DATA-12; 02-06-2025)
(Office of Origin: M/SS/CFA)
20 FAM 202.1-1 Data and AI Governance Pyramid
(CT:DATA-7; 10-15-2024)
a. This section outlines the roles and responsibilities for handling the Department’s data assets to 1) ensure compliance with guidance provided in the Foundations for Evidence-Based Policymaking Act of 2018 and 2) to establish processes for collaboration between bureaus, offices, posts, and the Enterprise Data Council (EDC) to create and enforce data policies, while supporting nimble working groups dedicated to addressing the Department’s most pressing data challenges.
b. Within the Department, enterprise data management responsibilities are exercised at the Executive, Strategic, Tactical, and Operational Levels (see Figure 1). These levels and the key stakeholders are laid out below. It is important to note, however, that while not all Department personnel can identify with one of the roles highlighted in the enterprise data governance framework, everyone in the workforce has a role in data policy compliance.
Figure 1: Data
Governance Framework
20 FAM 202.1-2 Executive Level
(CT:DATA-7; 10-15-2024)
a. The Executive Level, which consists of the Enterprise Governance Board (EGB), ensures organizational commitment to treating data as a strategic asset and leveraging it in decision-making at the Department by:
(1) Establishing the expectations and requirements that drive the data governance, data management, and data stewardship that occur at the Strategic, Tactical, and Operational Levels, respectively;
(2) Approving data initiatives and championing their development and implementation;
(3) Reviewing and approving how data governance, management, and stewardship are measured across the Department; and,
(4) Delegating responsibilities for strategic decision-making to the EDC.
b. 2 FAM 040 provides details on the role and responsibilities of the EGB.
20 FAM 202.1-2(A) Executive Governance Board (EGB)
(CT:DATA-7; 10-15-2024)
Reserved.
20 FAM 202.1-3 Strategic Level
(CT:DATA-7; 10-15-2024)
The Strategic Level, which consists of the EDC, serves as the Enterprise Data Governance Body of the Department, as required by OMB M-19-23. It sets and enforces priorities for managing data as a strategic asset to support the agency in meeting its mission.
20 FAM 202.1-3(A) Enterprise Data and AI Council (EDAC)
(CT:DATA-7; 10-15-2024)
a. The EDC is chaired by the CDO and comprised of Senior Department officials from each Under Secretariat deemed necessary by the Under Secretary for Management (M), including the Statistical Official and the Department’s Evaluation Officer(s). EDC membership, charter, and actions are regularly reported to OMB through the Federal Data Strategy. The EDC Charter provides details on the role and responsibilities of the EDC.
b. The EDC is charged with:
(1) Developing enterprise strategies and policies for data management in line with the expectations and requirements of the Executive Level and overseeing their implementation at the Tactical and Operational Levels;
(2) Advising on the action plans/roadmaps the Tactical Level develops to enforce alignment at the Operational Levels with the enterprise data strategies and policies;
(3) Resolving disputes between Department organizational units in instances where they cannot agree on data sharing and access parameters;
(4) Working with the Tactical Level to define and deliver effective means to measure bureaus’ adherence to data policies, facilitating the delivery of measurable metrics to the Executive Level; and
(5) Escalating issues to the Executive Level as appropriate.
20 FAM 202.1-4 Tactical Level
(CT:DATA-12; 02-06-2025)
a. The Tactical Level consists of Bureau Chief Data Officers (BCDOs), EDC Liaisons, and other stakeholders in bureaus, offices, and posts that represent their organization units’ data equities. These personnel are GS-14/15 or FS-02/01 level Department employees who are the “go-to” persons (below the DAS level) for all things data in their work units. Collectively, they support the EDC by guiding the implementation of the Data Management Policies (see 20 FAM 103) at the bureau level by:
(1) Identifying data domains and their data holdings and systems;
(2) Developing and implementing action plans and roadmaps to align domains’ management of data with the Data Management Policies;
(3) Promoting, directing, and coordinating the Operational Level activities of Data Stewards and working with them to facilitate education on Data Management Policies in their bureaus/offices;
(4) Defining and collecting metrics that assess the effectiveness and value of the data management efforts; and
(5) Elevating issues to the Strategic Level for action, as necessary.
b. These personnel may administer and support the Data Management Policies efforts by being a part of data-related working groups. Currently, the Department has five data-related working groups, and they align and operate under the EDC. They comprise senior representatives and bureau/post-nominated data experts who bring their organizational context to the collaborative development of policies or management processes that follow the Department’s data priorities and facilitate the Department’s compliance with federal legislation and guidance.
(1) Application and Data Coordinators Working Group (ADCWG) - Chaired by the DCDO, this working group consists of data stewards from across the Department. This group works closely with Data Custodians to create, modify, and publish Department data standards in the MRD.
(2) Data Scientist Practitioner Group (DS PG) - Chaired by the Chief Data Scientist (CDS) as the Department designated official for Responsible AI, as defined in 1 FAM 044. This PG serves as a coordinating body for Department bureaus and offices engaged in the design, implementation, and sustainment of AI and ML projects and programs. The PG helps ensure all Department work complies with AI and ML standards, principles, and best practices as required by Executive Order 13960.
(3) Electronic Records Management Working Group (ERMWG) - Chaired by the CDO, this working group consists of records management officials from across the Department. This group supports the execution of data retention and records management requirements, as led by A/GIS/IPS/RA.
(4) Enterprise Data Strategy Working Groups (EDSWGs) - Led by the Enterprise Data Strategy team in M/SS/CfA, these working groups align to the EDS Implementation Campaigns.
(5) Geospatial Data Act Working Group (GDAWG) - Consists of representatives from the Covered Agency Inspector Generals to support the Department’s 13 responsibilities and reporting requirements outlined in Section 759(a) of the Geospatial Data Act (43 U.S.C. 46).
(6) In coordination with the EDC, members of the Tactical Level may be required to create new working groups to satisfy new and evolving mandates. Similarly, they may sunset or modify any working groups whose mandates have been satisfied.
20 FAM 202.1-4(A) Data Governance Network (DGN)
(CT:DATA-7; 10-15-2024)
Reserved.
20 FAM 202.1-4(B) AI Steering Committee (AISC)
(CT:DATA-7; 10-15-2024)
Reserved.
20 FAM 202.1-4(C) Geospatial Data and AI Working Group (GDAWG)
(CT:DATA-7; 10-15-2024)
Reserved.
20 FAM 202.1-5 Operational Level
(CT:DATA-7; 10-15-2024)
a. The Operational Level consists of Data Stewards who are responsible for ensuring effective control and use of data assets. The Operational Level guides and monitors the implementation of 20 FAM 102 at the working-level on a daily basis by:
(1) Being well-versed in the Data Management Policies and any supplemental guidance the EDC issues;
(2) Informing and enacting the action plans and roadmaps the Tactical Level designs to implement the Data Management Policies;
(3) Measuring and reporting to the Tactical Level on performance in terms of accountability, efficiency, and effectiveness in handling data in accordance with the Data Management Policies;
(4) Assisting the Tactical Level in mapping data across disparate data systems and storages; and
(5) Educating Data Users on the value of data and its management requirements.
b. Data Users – who are Department employees or contractors – also play a key role in the data management efforts as they generate and/or use data as part of their official daily duties. They originate the data pipeline that drives decision-making all the way to the Executive Level and keeps the Department functioning. For this reason, they must understand the Data Management Policies (see 20 FAM 103) and procedures and must consult and follow Data Stewards’ guidance on how to apply them in their day-to-day duties.
(1) Data Users who generate data can do so by creating it (e.g.: by merging individual datasets), extracting it (e.g.: from a cable), or acquiring it (e.g.: from a database). These Data Users have the following responsibilities:
(a) Gather, verify, and document information on the origin (the name of the place data came from, if data did not come directly from the source, e.g.: DS Bureau), source (the name of the entity that produced data, e.g.: World Bank), and purpose of the data they onboard in accordance with the Department’s guidance to ensure standardization.
(i) Documentation must be developed before data is onboarded;
(ii) It is strongly encouraged that onboarded data comes from authoritative sources that are trusted because their authority or authenticity is widely recognized by experts in the field;
(iii) Once verified as authoritative, data must be designated as such; and
(iv) A statement of purpose must be developed before data is being onboarded and include:
· Contact information for the Data User who generated it;
· Date of collection and/or update;
· The reason for collecting given data; and
· Information on how and by what bureaus/offices or types of roles data can and cannot be used.
(2) Data Users who create data with the use of a code that they author or acquire from a third party have the following responsibilities:
(a) Ensure that code is clean, understandable, and accompanied by a step-by-step documentation on how to apply it and for what purpose. Data Stewards will review code and provide instructions on how to improve it if necessary;
(b) Define and publish code’s storage location;
(i) Save code together with the contact information for the Data User who designed it;
(ii) Develop documentation as the code is being created;
(iii) Save and publish code together with its documentation; and
(iv) Link code to the relevant product(s).
(3) Data Users who use data to complete their daily tasks have the following responsibilities:
(a) Use data in accordance with its statement of purpose; any other use must be justified, documented, and approved by the Data Steward (in a Data Sharing Agreement (DSA), if applicable);
(b) Use data as defined in the signed DSA;
(c) Use only data that is designated as authoritative, where it exists; and
(d) In case there are further questions about the statement of purpose, consult with Data Stewards on what can and cannot be done with the data.