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What Is Data Governance? A Practical Guide for Businesses

Data governance is the set of roles, policies and processes that decides who is accountable for data, what it is used for, how long it is kept and who can access it. This guide shows how to start and links it to Vietnam's Law 91/2025.

What is data governance?

Data governance is how an organisation decides and oversees the use of data: who is accountable for each dataset, why the data is collected, how long it is kept, who can access it and how its quality is measured. It is not a piece of software but a set of roles, policies and processes, which are then built into software.

For businesses in Vietnam, data governance is also the practical way to meet the 2025 Personal Data Protection Law (Law No. 91/2025/QH15, in force from 1 January 2026) and Decree 356/2025/ND-CP: the law requires processing for a defined purpose, consent for each purpose, retention only as long as appropriate, and deletion when the data is no longer needed.

Reference framework: DAMA-DMBOK puts governance at the centre

A widely used reference is DAMA-DMBOK (Data Management Body of Knowledge) from the professional association DAMA International. DMBOK divides data management into 11 knowledge areas, with data governance at the centre of the "DAMA wheel". The ten areas around it are data architecture, modelling and design, storage and operations, data security, integration and interoperability, document and content management, reference and master data, data warehousing and BI, metadata, and data quality.

DAMA describes DMBOK as principles and good practice that do not prescribe tools or technologies, and not a legal mandate. Version 2 is current; DAMA started the DMBOK 3.0 project in 2025. The practical lesson: small and medium businesses do not need all 11 areas at once. Start with governance (roles, policies) and extend to metadata, quality and security as needs grow.

Four core roles: owner, steward, custodian, user

The most common mistake is "data belongs to IT". IT runs the systems, but the business function understands what the data means and what it is for. The table below shows a common split of roles in data governance programmes. Names differ between organisations; what matters is that each responsibility has a named person.

Roles in data governance
RoleUsually whoAccountable forExample
Data ownerHead of a business functionDeciding purpose, access and retention; approving exceptionsHR manager for employee data
Data stewardBusiness specialistField definitions, quality rules, fixing errors, maintaining the data catalogPayroll specialist maintaining the definition of "start date"
Data custodianIT, system administrators, vendorsRunning storage, backup, technical permissions and logging as the owner requiresHRM system administrator
Data userEmployees, partners, AI AgentsUsing data only for the stated purpose and within granted access; reporting incidentsLine manager viewing records of their own team

How this maps to roles in Law 91/2025

The law uses different terms: the personal data controller (decides the purposes and means of processing), the processor (processes on the controller's behalf under a contract) and the controller-processor. A business is usually the controller; the data owner is the person inside the business who carries out those decisions. Software and cloud vendors are usually processors, so contracts should set out rights and obligations clearly.

The minimum set of data policies

Policies do not need to be long. A minimum set, one or two pages each, is usually enough to start:

  • Classification policy: levels (for example public, internal, confidential, sensitive personal data) and handling rules for each.
  • Access policy: role-based access, who approves, periodic access reviews, revocation on role change or exit.
  • Retention and deletion policy: retention period per data type, the basis (sector law, contract, purpose) and secure deletion.
  • Quality policy: mandatory fields, validation rules, who fixes errors.
  • Procedures for data subject requests and data incidents.

Data catalog and classification: know what you hold

You cannot govern what you do not know you have. A data catalog lists datasets: which system, who the owner is, which fields, whether it contains personal data, the purpose and the retention period. For a small business, a well-maintained spreadsheet is enough to start; a dedicated catalog tool is only needed as the number of systems grows.

Classification lets you apply the right level of protection. Under Law 91/2025, personal data is either basic or sensitive, according to lists issued by the Government, currently Articles 3 and 4 of Decree 356/2025/ND-CP. Tag fields that hold sensitive personal data in the catalog so stricter rules apply.

Sample catalog entry (Illustrative example)
FieldSample value
DatasetCandidate records
SystemApplicant tracking system (ATS)
Owner / StewardHR manager / Recruiter
Contains personal dataYes; no sensitive data collected
PurposeRecruitment for the open position
BasisCandidate consent
RetentionDelete if the candidate is not hired, unless otherwise agreed (Article 25(1), Law 91/2025)
Who can accessRecruitment team and the interview panel for the role

Mapping governance rules to Law 91/2025 and Decree 356/2025

The four original rules of this article (an accountable owner, purpose, retention, role-based access) line up with the law's main obligations:

Governance rules and legal basis
RuleWhat the law requiresWhat to do
Every dataset has an accountable ownerThe controller decides purposes and means and is accountable to data subjects; businesses designate a data protection unit or person, or use a service providerName an owner in the catalog; designate a data protection contact
Record the purpose at collectionArticle 3: collect and process only within a specific, clear scope and purposeEvery field has a purpose; no purpose, no collection
Consent for each purposeArticle 9(4): consent per purpose, no forced consent to other purposes, silence is not consentSeparate consent boxes by purpose; keep proof; offer withdrawal
Retention is a decisionArticle 3: keep only as long as suits the purpose; Article 14: delete when the purpose is fulfilled or the retention period ends, using secure methodsRetention matrix; automatic deletion schedule; deletion records
Role-based accessArticle 3: apply institutional, technical and human measures together to protect dataRole-based permissions, periodic review, access logs

Build governance into software, not just documents

Policies only work when built into everyday tools: mandatory fields and format checks at entry, role-based permissions instead of shared accounts, automatic deletion on retention schedules, searchable access logs, and consent boxes separated by purpose on every form.

This matters even more when AI enters operations. An AI Agent is also a "data user": it needs least-privilege access, an action log, and should read data only for its stated purpose. Before deploying AI, see the data readiness for AI checklist and access control and audit logs for AI Agents.

A five-step starting plan

EYC designs cloud and data infrastructure with access control, logging and data lifecycle built into the system. If you need a specific system reviewed, contact EYC.

  • Step 1: List the main systems and datasets; assign an owner to each.
  • Step 2: Build a minimum data catalog: purpose, personal data or not, retention, who has access.
  • Step 3: Review collection forms: remove fields without a purpose, separate consent by purpose.
  • Step 4: Set up role-based access and deletion schedules; turn on access logging.
  • Step 5: Check documentation duties under Law 91/2025 and Decree 356/2025, such as the personal data processing impact assessment; see Vietnam's Personal Data Protection Law 2025 and Decree 356/2025.

Frequently asked questions

How is data governance different from data management?

In the DAMA-DMBOK view, data management covers many areas such as architecture, storage, integration, quality and security. Data governance is the central part that sets roles, policies and accountability so those areas work consistently.

Does a small business need data governance?

Yes, at a minimum level. Law 91/2025 applies to every organisation that processes personal data. A spreadsheet data catalog, one owner per dataset, purpose-based consent forms and a deletion schedule are a reasonable starting point.

What is the difference between a data owner and a data steward?

The owner makes decisions and is accountable (usually a business head). The steward does the daily work: defining fields, maintaining quality, updating the catalog. The custodian (usually IT) runs the systems as the owner requires.

Can one consent cover several purposes?

It should not. Article 9(4) of Law 91/2025 requires consent to be given for each purpose, without conditions forcing consent to other purposes, and silence is not consent.

How long should personal data be kept?

There is no single number. The law requires keeping data only as long as suits the purpose, unless another law sets a specific period (for example accounting records). Each data type needs a retention period and basis recorded in the catalog.

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Key point

Data governance starts with four questions: who is accountable, what is it for, how long is it kept, who can see it. Answer them for each dataset, record them in a catalog and build them into software, and the business gets more trustworthy data and a foundation for meeting Law 91/2025 and Decree 356/2025. This article is for information only and is not legal advice.

Sources

  1. Data Management Body of Knowledge (DAMA-DMBOK) — DAMA International
  2. DAMA-DMBOK Framework: 11 knowledge areas — DAMA DMBOK
  3. The DAMA Wheel: governance and the 10 knowledge areas — cimt
  4. Luật số 91/2025/QH15: Luật Bảo vệ dữ liệu cá nhân — Cổng Thông tin điện tử Chính phủ
  5. Quy định về sự đồng ý của chủ thể dữ liệu cá nhân từ 01/01/2026 (Điều 9) — Thư Viện Pháp Luật
  6. Xóa, hủy, khử nhận dạng dữ liệu cá nhân từ 01/01/2026 (Điều 3, Điều 14) — Thư Viện Pháp Luật
  7. Luật Bảo vệ dữ liệu cá nhân 91/2025/QH15: tóm tắt — LexData
  8. Tin nhanh pháp lý: Luật Bảo vệ dữ liệu cá nhân — EY Việt Nam
  9. Nghị định số 356/2025/NĐ-CP — Văn bản Chính phủ
  10. Nghị định 356/2025/NĐ-CP: tóm tắt và hiệu lực — LuatVietnam
  11. Luật Bảo vệ dữ liệu cá nhân số 91/2025/QH15 (toàn văn: Điều 9, 14, 25) — LawPlayer

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