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Governance · Committee

Information Governance Committee

The Information Governance Committee decides what data the group holds, on what lawful basis and for how long. No dataset enters the Information and Data division until the Committee has seen its origin, its licence terms and its retention schedule. It keeps the register of datasets and reviews the whole register in each quarter, including the datasets that arrived with an acquired business.

Chair
Priya Vantongeren
Members
4
Meets
Quarterly, and within ten working days of any incident affecting client or personal information.
Reports to
The Board of Directors, with model questions referred to the Ethics & Technology Council.

Remit

It is the escalation point for any incident affecting client or personal information. It sets notification thresholds, approves data sharing with counterparties, administrators and vendors, and applies the restraint principle: nothing is inferred about an individual beyond what the mandate requires. Requests to enrich a client record with information the client did not supply are refused and recorded.

Decisions reserved to the committee

  • Admission of a new dataset to the register.
  • The lawful basis and retention period recorded for each dataset.
  • Notification thresholds and incident escalation.
  • Data sharing with counterparties, administrators and vendors.
  • Refusal of enrichment requests that fall outside a mandate.

Membership

4 members.

MemberRoleBased
Ottoline Baskerville-NakamuraHead of Technology and EthicsSingapore
Fenella Marsh-AdeyemiGeneral Counsel and Group Head of ComplianceLondon
Sable Okonjo-LindqvistChief Operating OfficerLuxembourg
Dmitri Halloran-VeigaChief Risk OfficerZürich