Still Defining The Undefineable?

Solvency II Data Directory Data Governance

This week I am reposting an updated version of a blog, which I originally posted last February. The reason for the repost is that now Solvency II timescales are confirmed, the topic is very much back on the agenda. So much so that I have been asked to repeat the Solvency II Data Quality Course I originally did last year.

In February last year, I presented a webinar entitled "The Solvency II Data Directory – How to Make it Valuable to Your Business Today" for Dylan Jones of (a recording of the webinar can be found here if you missed it and are interested).

It was the first webinar I had ever presented and as with my whole approach to Data Governance, I believe that you have to take your opportunities when they arise. I was preparing to deliver a training course "Data Quality and Governance for Insurers – Getting the Most From Your Solvency II Data Initiatives" and when I mentioned to Dylan that I working on the course content, he immediately asked me to present a webinar on one of the modules.

Whichever of the modules I had chosen, it was always going to be a niche topic, so I was extremely surprised (and flattered) by the number of people who signed up for and joined the webinar. Obviously the challenge facing European Insurers of what to do with their Data Directories while Solvency II deadlines keep slipping is something that a lot of people are worrying about at the moment.

The Data Directory is one of those deliverables that suffer greatly from a lack of definition – which is a particularly sad thing in a data deliverable so whilst data people in Insurance companies may understand the high level concept and may be able to explain in detail what is in their "Data Directory" they are struggling to make it add value to the business as well as getting that tick in the regulatory box. The task is being made even more difficult because I do not believe that you will find any two data directories which have exactly the same content, because there is no detailed definition of what should be included just the following concept:

"a directory of the data, specifying their source, characteristics and usage and the specification for the collection, processing and application of the data"

There are a number of data related deliverables required for Solvency II and some of them could easily be stored in the Data Directory, alongside details of the source, characteristics and usage of the data used in the Solvency II calculations. Which you choose or have chosen to hold, will heavily influence how you can get added business value from your Data Directory.

As and when we get more detailed Level 3 guidance from EIOPA, it might become clearer exactly what they want in our Data Directories, but until then I recommend that you define and document well what is in yours and in the meantime work with what you have to support existing business processes, so that the considerable effort you have invested adds benefit to your business now rather than waiting for the Solvency II deadlines.

Finally if you can be in London on the 8th April, there is still time to book on the course "Data Quality and Governance for Insurers Under Solvency II" and you will receive a 20% discount if you quote DATA1 when booking.


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