DIR and TSLAC Guidance Document: Governing Data, Records, and Information Together

How does our agency designate a DMO?

Reach out to DIR and notify them of the designation: OCDO @ dir.texas.gov.

Who must be the DMO? 

One of the agency’s full time employees. The requirement does not specify if the agency must designate an employee whose main focus is the DMO role or if the role can be an additional job duty. This is likely because that decision is best left to the agency to decide, due to agencies varying widely in number of employees, data classification, funding, etc. 

Who should be the DMO? 

The most ideal candidate for the DMO is a person familiar with data, data governance, and the connection between data, records, and information. However, don’t fret if this employee does not yet exist at your agency or if you are the DMO and are not familiar with one or all of these concepts, because they can be taught to those interested! 

Some soft skills an employee designated as the DMO should have are a creative thinker who is curious, a go-getter, and is willing to listen and learn from others. The DMO must be willing to set up interdepartmental meetings to connect, pitch themselves and data governance as an asset rather than an obstacle, and listen to each department’s opinions. For meeting attendees, the DMO should look for a person from each department who is aware or willing to find out how a change to policies, procedures, or general operations would affect the key stakeholders in their department. We recommend limiting the meeting to one person per department to refrain from having too many cooks in the kitchen.

Prior to stepping in the meeting, the DMO should familiarize themselves with data, data governance, the DMO’s role and responsibilities, and each department’s goals, priorities, and a general understanding of their functions. This insight and background knowledge provides the DMO with clarification on how to proceed with agency policies, procedures, or operations affected by data governance.

When first beginning or if receiving push back, the DMO should be a person who is willing to seek out influencers in their agency that can help clarify any misunderstandings that gatekeepers in their agency have. Again, the DMO should be a creative thinker who can listen to the gatekeeper’s concerns to effectively discuss and land on a solution beneficial for the agency. One reason for push back tends to be miscommunication, so the DMO should be willing to learn different department’s terminology to effectively communicate. Check our Tip #3 in our article, Obtaining: Buy-In: Records Creators and Users to explore the idea of a “corporation dictionary”.

Can the RMO and the DMO be the same person?

Yes, in fact some agencies are choosing to do this! 

TSLAC is one of those agencies because we are small-medium sized, only have a few divisions, and most of our data is public. This means that TSLAC does not not require a large number of policies, procedures, and protocols to be set, so it is not overwhelming for one person to manage both programs. Remember, it’s up to your agency to determine what is best for their programs.

Woman holding up hand for high five and then high fiving herself. She mouths "yes", clenches her fist, and brings her arm down to indicate she is excited.

What are the DMO’s official duties? 

The DMO’s official duties are outlined in Government Code, Section, 2054.137 and DIR also lists the DMO’s duties, which we recommend reviewing. 

Briefly outlining some of those duties… 

  • They must coordinate with the Chief Data Officer at DIR, TSLAC (specifically, their agency’s Government Information Analyst), and their agency’s RMO and Chief Information Officer. 
  • They must establish a data governance program in accordance with DIR’s guidelines.
    • The guidance document is an example of DIR’s guidelines. 
    • An example of meeting this requirement is TSLAC’s Information Governance Committee (IGC) and subcommittee, the Technology Review Committee (TRC). The IGC consist of department heads, the DMO, and other executive-level decision makers as applicable. The TRC consists of 2 staff members from each department. To remain aware of software as a service (SaaS) products that contain TSLAC data to ensure control over data throughout its lifecycle, both committees work together to determine if TSLAC should procure a SaaS. For any SaaS that a TSLAC staff member is interested in using, they are required to submit a form for TRC’s review. Once TRC has reached a conclusion as to if TSLAC should procure the SaaS, they submit their findings to the IGC. One of the IGC’s roles is to determine if TRC has found enough information to provide basis for their answer. When necessary, procurement, legal, and the agency head are involved in the process.
  • The DMO must exercise authority over data assets by creating and establishing policies and procedures that govern data, set the criteria for data retention, and determine who will be the data’s custodian.
    • At TSLAC, one way we meet this requirement is by asking staff members who propose a SaaS to the TRC to determine who will be the data’s custodians and a series of questions to determine how the data will be managed. We also ask if the data FedRAMP or TX-RAMP compliant and if the it can be found on DIR’s contract list?
  • The agency must publish three data sets to the Texas Open Data Portal. The data assets must be information that can be made accessible to the public. Ideally, the data sets will be information that is frequently requested by the public, so agencies can provide quicker and easier access to the requestor.  

If I’m a state agency with less than 150 FTE or a local government, can I still designate a DMO?

Yes and yes, but you are not required to; nor do they have to be called the “Data Management Officer.” In the modern business and records management world, data is everywhere, so all government entities should be considering data governance in their policies, procedures, and general operations. If a government entity would like to designate a person who is responsible for researching, developing, and rolling out these policies and procedures into general operations, then we say “go for it!”

Since your entity is not required to designate a DMO, Government Code, Section, 2054, the guidance document, and any other resources targeted to DMOs can be used as a benchmark tool.

How long do I keep data?

It depends on the purpose of the record that that contains the data. TSLAC does have a few record series specifically for data. Generally, the data will be the elements that make up a record. The record serves a purpose for your entity and the retention period is determined based on that purpose. This is why RMOs and DMOs need to connect, because the RMO will be able to determine how long to keep data by determining how long to keep the record. 

If the data cannot be classified within a “state record,” then it is up to your agency to determine how long to keep the data based on the data’s administrative value (or business purpose). When deciding how long to keep the data, just like you would for records, make sure to account for the data’s environment. Who is managing the data? How sensitive is the data? How long should we keep this without increasing an unnecessary risk or cost for our entity?

I’m not sure we have data. Are we still required to have a DMO?

If you are a state agency with 150+ FTE, then you are required to have a DMO. Also, and absolutely no shade, but if your agency has electronic records, computer applications, or computer systems, then you have data. 

For those familiar with electronic records, we recommend looking at the definitions for and examples of “unstructured data” and “semi-structured data”. Some examples that you will be familiar with are word processing files, email, and social media. The individual symbols or characters that make up an electronic record are data.

In a response to, "I'm not sure we have data." GIF that says "Bro. You have data." With guy in the center knowing that he just roasted the person. Surrounded by his friends who are showing that they can't believe how bad he just roasted them by walking around, gasping, and putting their hands to their face in shock.

The confusion likely stems from thinking of “data” as the definition for and examples of “structured data,” which will be the data the DMO generally handles or is more familiar with. For further guidance on the difference between data, records, and (again, always involved) information, checkout our article, the Relationships Between Data, Information, and Records.

Are agencies required to use the Data Management and Analytics Maturity Assessment (DMAMA) developed by DIR?

No, but the agency must conduct an assessment on their data program. The assessment will help agencies determine how vulnerable their data program is to identify where resources need to be applied. 

An alternative is ARMA’s Principles, which are also discussed in the guidance document. 

Any quick tips?

  • We recommend attending the Data Management Advisory Committee (DMAC) to hear updates, remain involved, and make friends. For further information, reach out to the Chief Data Officer at DIR: OCDO @dir.texas.gov
  • Register for the eRecords conference hosted by DIR and TSLAC every November to hear from records leaders about strategies, solutions, and considerations for properly managing electronic records and data. The conference is targeted to Texas government entities. Don’t forget to invite your RMO/DMO and to debrief together afterwards!

Once this information has settled, where can I go to continue learning? 

  • To close any knowledge gaps you have related to data, take courses offered via DIR’s Texas Data Literacy Program
  • To become familiar with how data and records relate, checkout the following TSLAC resources.
  • Reach out to other agencies to make friends to lean on and discuss your dreams, struggles, and achievements with. Some close friends will be entities who have designated the DMO and RMO in a similar way, similar data or considerations based on data classification, or are using SaaS that your entity is considering.

For further questions, please reach out to… 

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