• Risk
  • Blog
  • Mohit Modi
  • Global Research and Risk Solutions
  • Banking
  • Data Centre
June 01, 2023

Being a good information fiduciary

by Mohit Modi, Head of Data & Analytics, CRISIL Global Research & Risk Solutions

 

 

As trustees go, there is one that has been gaining prominence in recent times - the information fiduciary.

Traditionally, the concept of a fiduciary has been associated with someone who manages your money or your business on your behalf.

Banks, asset managers and pension funds have a fiduciary duty towards their principal, on whose behalf they act.

Similarly, management teams have a fiduciary duty towards their shareholders.

In these cases, the rules of engagement evolved over centuries and role-specific regulations and regulators also evolved over time to enforce compliance.

In contrast, the information fiduciary is an entity that manages your sensitive information and has a duty to safeguard it.

Traditionally, the scope of information was limited, and the fiduciary role was played by a limited number of regulated players, such as rating agencies, wealth managers, and accounting/ audit firms.

Today, the definition of sensitive information has widened and any analytics firm that accesses a customer’s information arguably becomes an information fiduciary.

The task is equally, if not more, onerous but with two key operational differences from that of traditional fiduciaries:

  • Information is replicable. A misstep by a fiduciary can lead to copies of information getting leaked to multiple outside recipients 
  • Information loss is irreparable. Unlike financial loss that can have possible monetary reparations, information loss can't be compensated

In the context, the responsibilities of an information fiduciary extend beyond those of a traditional fiduciary.

That said, the rules of engagement as well as regulations are still evolving and, often, it becomes very difficult to assign accountability of loss.

Traditional fiduciaries, who also become information fiduciaries via their analytics offerings, can lead from the front in setting self-governance norms.

Traditional fiduciaries

Implementing these norms requires an exercise in change management and in building a culture of responsibility, both of which are not easy.

Analytics firms have long focused on solving their clients’ problems, sometimes ignoring their role as information fiduciaries. Those who understand their roles as information fiduciaries and build governance controls will eventually win trust of stakeholders and hold competitive advantage in the long run.