The Eighth Day of BCBS 239: Traceability

By Stephen Engdahl | 15 December 2014

Is the critical data you use in risk analysis so transformed that it has become just a shadow of its former self? Where did your data originate? Who touched it and where did it go along the way?

When it’s time to make decisions regarding risk, traceability is key, just as when writing thank-you notes at the holidays. A BCBS 239-ready data management operation must be able to trace critical data forward from source to use, or backward from use to the source.

  • BCBS 239 Principle 1 indicates that risk data aggregation practices must be fully documented and subject to third party validation.
  • BCBS 239 Principle 2 discusses source-to-use processes and controls.
  • BCBS 239 Principle 12 requires banks to be able to discuss aggregation capabilities with auditors – a discussion which must be substantiated with evidence.

Key elements driving data lineage and traceability include 4-eyes controls to ensure accuracy when critical data elements are subject to any sort of manual intervention. It also includes audit trails for every transformation, manual or automated, including approval steps. Further, it requires bi-temporal history, to allow reconstruction of point-in-time information as well as adjusted as-of information. Accessible access points allow business users to ask questions and get clear answers regarding specific data lineage questions – such as inquiry screens, reports, and analysis tools.

Data lineage can be linked to your data governance framework, particularly if your governance framework is integrated with your operational systems and processes. Both data consumers and data stewards need visibility into the data supply chain on which they rely.

With this eighth day of BCBS 239, we’ve concluded our exploration of four critical capabilities of data management for risk data aggregation - quality, timeliness, flexibility, and traceability. Now that G. Sibley has his core capabilities in place, it’s time starting tomorrow to explore how he can use this to the best advantage for his bank. Join us tomorrow as we explore how BCBS 239 success translates into improving your competitive edge.

Look out for day nine tomorrow.


By Steve Engdahl, SVP, Product Strategy, Goldensource 

Become a bobsguide member to access the following

1. Unrestricted access to bobsguide
2. Send a proposal request
3. Insights delivered daily to your inbox
4. Career development