Dutch bank builds better compliance with Collibra

ASN Bank is a retail and (small) business bank in the Netherlands with over three million customers. Products include payments, mortgages, savings and SME loans and sustainable investment funds. The bank is positioned as a ‘sympathetic challenger’ to the three biggest Dutch banks, standing out due its customer contact and focus on ESG goals.

Data is at the core of the bank’s business operations, particularly in risk management and crime prevention. Data also underpins understanding, communicating and marketing to prospects and its customers. Like many organizations, ASN Bank's data storage and systems began long before more stringent regulations for transparency took effect. The initial trigger for the upgrade in data management capabilities was the recently increased emphasis on improved compliance with the General Data Protection Regulation (GDPR).

As the bank sought to improve GDPR compliance, the new capabilities also proved valuable to meet financial regulations, such as the Basel Committee on Banking Supervision’s (BCBS) Standard 239 (BCBS 239). This standard was implemented following the global economic crisis and enforces thorough transparency in the way that financial institutions aggregate and report data on their risk positions. Just like GDPR, it all boils down to knowing what (personal) data the bank stores in the first place, how it is processed along the data value chain and which controls are in place to safeguard data quality and usage.

Now, with Collibra implemented, when Dutch and European financial authorities ask ASN Bank about compliance with regulations like BCBS 239, the bank demonstrates how it meets the regulations, specifically what data it uses, who owns the data, where it comes from and how it is used. To reach this point, the bank has been on a steady journey of data governance improvement.

Before the introduction of Collibra, legacy systems and processes required the bank to spend excessive time and effort managing data to meet compliance requirements. Different and disconnected teams held and managed data. Separate risk reporting, data stewardship and data warehouse departments duplicated processes, and teams controlled the data using spreadsheets.

ASN Bank launched a Transformation Program that targeted business restructuring, improved customer service and better data quality. As part of the program, ASN Bank created a new, 200-strong data organization called the Expertise Center Data (EC Data). EC Data also took responsibility for the development of a modern and centralized cloud-based data platform, with Collibra positioned as the data governance solution.

“The aim was to do risk data management and crime prevention in a more transparent and compliant way. We integrate multiple areas from the ‘metadata world’, including definitions, lineage and quality. What information do we maintain about customers, transactions and products, how does it all relate and what do we do with it?” stated Kasper Kisjes, Enterprise Data Catalog Implementation Lead, ASN Bank. “This is the sweet spot of Collibra, providing a clear structure of metadata, supported by workflows, governance and ownership.”

ASN Bank chose Collibra as its data governance solution because of its configurability. “The way metadata is modelled and documented in Collibra flexibly follows how our business functions and operates,” explained Kisjes. “Some alternative solutions force you to model in a fixed way so that you have to make your organization follow the application.”

The bank’s existing data management solution was nearing the end of its life cycle and needed replacement. Erwin Oppelaar, Enterprise Data Architect at ASN Bank, said, “Some of the solutions we looked at meant we would be locked into their platform. Collibra’s ecosystem is independent, has good interoperability capabilities and allows us to harvest data from many sources.”

ASN Bank collaborated with its IT partner, Valcon, and Collibra to deploy the Collibra unified platform as the foundation for data governance, with plans to roll out two additional modules: Collibra Data Quality & Observability and Collibra Protect. The implementation approach was highly iterative, focusing on the one-by-one delivery of new modules at the level of Minimum Viable Products, connected to high priority use cases, and then building on top of that in an agile way. The first use case, data issue management, went live within just two months, with migration and overhaul of their business glossary and data definitions completed a few months later. Collibra integrates with several complementary applications, including Teradata, PowerDesigner, AWS, Snowflake and ServiceNow.

Surprisingly, ASN Bank’s first use of Collibra was establishing a central data issue repository for registering and remediating data issues. “By centering around data, everything we built in Collibra was directly relevant to the business from the early beginning, creating very tangible business value. We started by listing data issues, then used Collibra to relate the issues to data elements, physical data, reports, governance, processes and so on. That gives us a purpose-driven and valuable process for managing data effectively and demonstrating control,” commented Kisjes. “Having an overview of all issues, knowing where they are registered, how long they take to resolve and who is responsible drives towards more operational efficiency and better data management.”

ASN Bank structured its Collibra implementation around four central layers: 1) a glossary to define business terms 2) an enterprise data layer that represents the primary data objects and elements as a basis for data ownership 3) a logical layer for functional descriptions of the main dataflows and 4) a technical layer to manage access to data tables and columns that can be queried for reports. Supporting this architecture are modules such as the data quality repository, the reporting repository and a data marketplace (currently being developed) for publishing and consuming data. Collibra served as a key accelerator for the bank's strategy to treat data management as a high-priority capability.

The bank is now using Collibra to help improve BCBS 239 compliance by mapping which data a risk indicator depends on, as well as definitions and quality rules. “Previously, when asked how we control publicly reported liquidity risk, tracing the data lineage was a time-consuming activity with results that are hard to interpret from a business perspective,” explained Kisjes. “Now, because of Collibra’s interconnections within and between the central layers, we can quickly and easily trace where the data comes from and who manages it, to enable e.g. accurate liquidity risk assessment. A simple web page in Collibra provides access to the information we need for compliance.”

Auditing reports that were previously managed with spreadsheets are now stored in a Collibra report repository, where they are numbered, have identified owners, and linked to relevant, clearly defined KPIs. “Collibra allows us to easily see how data flows between KPIs and reports, which data elements are connected, who is responsible and what the current quality of the data is,” added Oppelaar.