XIMNET - The Leading Tech Agency In Malaysia
Data Governance

Effective date: September 29, 2022

The purpose of this policy is to ensure that data management responsibilities and principles apply to the management, security and use of XIMNET corporate data assets and forms part of XIMNET’s internal control and corporate governance arrangements.


All staff or anyone performing work on behalf of the Organisation (also referred as XIMNET), including contractors, consultants and volunteers, must comply with this policy. This policy extends to its affiliated organisations, including its controlled entities, namely business enterprises and research centres majority owned by the Organisation, and as defined in the Data Governance Framework Policy.

This policy applies to all corporate data that in respect of which XIMNET has rights regardless of:

form – electronic or printed; structured or unstructured
media – internal network, cloud or hosted by a vendor
source – primary, duplicated, business intelligence or a republished copy

The focus of this policy is primarily institutional data. Management of data associated with academic research activity will be covered by the Data Management Policy which will address the specific requirements at a more detailed level.


XIMNET asserts its rights in respect of all data that is created and captured during the operation of the XIMNET. All corporate data must be managed therefore individual units or departments may have stewardship responsibilities for a defined segment of data. XIMNET asserts its rights in respect of all research data generated by research projects conducted at or under the auspices of XIMNET regardless of funding source, unless specific terms of sponsorship, other agreements or XIMNET policy supersede these rights.


XIMNET is committed to the implementation of data management practises which are based on the following principles:

Data is a managed asset: Data is an asset that has value to the organisation, and as such is managed accordingly. Each data set has a custodian and steward that ensures the data is fit for purpose.

  • Create an Information Management Strategy to identify opportunities, reduce business risk and align information investment to the business strategy.
  • Need to educate users to appreciate the value in accurate data that is fit for purpose.
  • Sources of data need to be identified, classified and assigned a Data Custodian.
  • Data Custodians must have the authority and means to manage the data for which they are accountable.
  • Data Stewards are essential because incorrect on inconsistent data could be used in decision making.
  • Procedures need to be developed to prevent and correct errors.

Data is shared: Users have access to the necessary data to perform their duties; therefore data is shared across enterprise functions and applications while maintaining security and data integrity.

  • To enable this we must develop and abide by a common set of policies, procedures and standards governing data management and access.
  • Need to document our data including data models and metadata and make it accessible.
  • Need to develop common methods and tools for sharing data e.g. application integration.
  • Under no circumstances will sharing data cause confidential data to be compromised

Data is accessible: Users are able to use the data to perform their functions.

  • Accessibility includes the ease with which users can access the data and obtain information.
  • It must be sufficiently adaptable to meet a wide range of users.
  • Users need to take responsibility to understand the data and caution not to misinterpret it. • Access does not mean privileges to modify or disclose the data.

Data is understood: Data is defined consistently and the definitions are understandable and available to all users.

  • Critical to improving information.
  • All data needs to be defined and the definitions need to be available to all users.
  • When a new data definition is required the effort is co-ordinated and reconciled with the Organisation’s metadata repository, which includes the glossary of terms.

Data is secure: Data is protected from unauthorised access, use and disclosure.

  • All data needs to be classified, including duplicated, aggregated and/or transformed data, and indicate if it contains personal information.
  • In order to adequately provide access to open information while maintaining secure information, security must be identified and developed at the data level, not the application level while ensuring that data is shared and available as required.
  • Security needs to be designed at the beginning. Applications, data and technologies must be protected from unauthorised access.
  • Data sources containing personal identifiable information (PII) and/or private information must be inventoried.


All corporate data must be managed and as such have representation by all the groups mentioned below. These are delegated responsibilities and ownership of data is retained by the Senior Leadership Team (SLT) of XIMNET.

The Information Technology Services department is responsible for:

  • promoting the value of Organisation data for enterprise use while facilitating sharing, integration and security
  • providing data architecture services that leverage a data reference model, manage an enterprise data classification and create an inventory of corporate data assets
  • documenting, managing and distributing data models (conceptual, logical and/or physical) of XIMNET data including relevant metadata and data integration
  • designing and managing processes for maintaining the integrity, accuracy, timeliness, consistency, standardisation and value of data including master data management
  • providing advice and support for the data stewards, data custodians and the data governance committee members
  • designing, managing and implementing data management policies, standards and frameworks in consultation with relevant key stakeholders
  • creating and/or reviewing database designs that align with relevant standards ensuring the principles are applied e.g. access and security
  • providing storage infrastructure and operational database support including managing the database management system platform, backing up databases and monitor/improve database performance
  • providing guidance on use and implications of the different storage options to ensure it is fit-for-purpose
  • ensuring appropriate procedures and systems are in place to support business continuity and disaster recovery.

The Data Custodians are responsible for:

  • assigning Data Stewards for data in their area of responsibility and allowing time for them to complete relevant tasks
  • managing and resolving data related issues that cannot be resolved by the Data Steward
  • authorising security classification of assigned data, e.g. public, restricted
  • authorising access to assigned data and its usage in other systems
  • identifying and registering personally identifiable information (PII) contained in data sources
  • applying and managing the ethical processes (where required)
  • ensuring that data is fit-for-purpose including defining data quality levels, metrics, business rules and facilitating data integration.

The Data Stewards are responsible for:

  • implementing and monitoring access to corporate data in accordance to approved business rules and processes
  • developing business terms and definitions (metadata) for assigned data sets and attributes, and ensuring that they are properly reviewed and approved in alignment with the Data Governance Framework
  • implementing and maintaining data quality requirements and business rules for assigned data sets
  • identifying and helping to resolve data issues, risks and errors (escalating to Data Custodian when required)
  • arranging appropriate training for staff to ensure that data is captured and used accurately and appropriately
  • providing input into data policies, standards and procedures
  • managing, mitigating and, where necessary, escalating data related risks
  • providing advice and permission for data when it is republished, duplicated or integrated with other systems
  • assisting users to ensure relevant data complies with the related policies in place
  • ensuring that all data that is not a record has an appropriate retention and disposal schedule
  • championing the implementation of data management standards and processes.

The Data Governance Committee members are responsible for:

  • defining the strategic enterprise data priorities
  • reviewing, approving and applying architecture practises
  • approving and endorsing any data policies, processes, standards and guidelines
  • planning and sponsoring data management projects and services
  • communicating and promoting the value of data assets
  • managing and resolving data related issues that cannot be resolved by the data custodian
  • monitoring compliance to policies, standards and regulatory legislation

Users are responsible for:

  • complying with data management policies, processes and standards
  • ensuring that all data access and usage is relevant and appropriate to the work being undertaken
  • observing any access controls or security restrictions that apply to the data to which they have access, and only working within the data access boundaries that they have been permitted
  • preventing any unauthorised access to data to which they have access rights, and ensuring that confidential or restricted data is always protected without disclosure to any unauthorised persons.

Retention and Disposal

XIMNET corporate data may often reside in the records or may of itself be a record. The retention and disposal of this type of institutional data must be managed in accordance with the Global Privacy Policy. The responsibility for retention and archiving of research data lies primarily with the Principal Investigator of a research project.

Data Breach Response

Our data breach response process follows a structured and detailed workflow to ensure that breaches are addressed in a timely and compliant manner. Upon identification of a potential data breach, our dedicated data protection team initiates an immediate investigation to assess the scope and severity of the breach. This involves gathering relevant information, such as the nature of the breach, the type of data affected, and the potential impact on individuals' privacy rights.

Following the investigation, we take appropriate measures to mitigate the breach's impact and prevent further unauthorized access or disclosure of personal data. Additionally, if required by law or regulation, we promptly report the breach to the relevant data user, data controller, or supervisory authority, providing detailed information about the breach and our response actions. Our goal is to ensure transparency, accountability, and compliance with data protection laws and regulations while safeguarding the privacy and security of individuals' personal data.


Business intelligence is a set of theories, methodologies, architectures, and technologies that transform and integrate raw data into meaningful and useful information that provides the business community easy access to data that supports decision making.

Data (corporate) is facts, figures or individual pieces of information that is captured through the operation of the Organisation and can be words, numbers or images etc. Data is the raw detail that can be used to represent information or, from which, information can be derived. All data needs to be managed regardless of what type it is. The types are: structured or unstructured.

Data Custodian is an individual who is a Senior Organisation staff member who has planning and policy-making responsibilities for data within their functional areas and management responsibility for defined segments of corporate data. They are expected to undertake any strategic work on data management.

Data governance is the formal management of data assets through the establishment of processes, maintenance of common standards and exercising positive control; it includes managing, improving, monitoring and protecting an organisation’s data and information. This then supports business intelligence and master data management initiatives, facilitates migration of legacy data, meets compliance and legislative requirements and improves corporate flexibility and business agility.

Data Governance Committee is the strategic decision making body for data governance and oversees the implementation of the Data Management Framework. It is the cross-functional team that makes policy decisions and includes senior representation for core services, records management, privacy officer and technical stakeholders.

Data management is the function that develops, manages and executes policies, processes, standards and frameworks that collect, protect, deliver, and enhance the value of data and information assets to meet the data availability, quality and security needs of the Organisation.

Data quality includes accuracy, completeness, timeliness, trustworthiness, business rules compliance, consistency and ability to integrate.

Data reference model is a data architecture framework to enable information sharing and reuse by standard description and identification of common data. It promotes good data management practises. The reference model at Massey leverages the framework developed by the Malaysian Government.

Data Steward is an individual who is a subject matter expert that does the day-to-day management of the operational requirements, data quality, compliance with requirements, conformance to policies and standards, security controls, and identifying and resolving data issues. They undertake any operational work on data management.

Duplicate source means a copy of the primary source often used for integration and/or reporting. The duplicated data may have been changed or aggregated through a managed extract, transform and load process.

Ethical processes apply to all research and relate to how data is collected, stored, accessed and managed. The ethical requirements for data may differ, and supersede, from that stipulated in the data management policy document.

Enterprise Data Classification provides a framework with definitions and diagram conventions for data models. It is a hierarchy that is also used to recognise the different data types, apply master data management and data governance. There is only one enterprise data classification that is then used for multiple conceptual and physical data models.

Information is data that has been interpreted so that it has meaning for the user.

Institutional Data is defined as all data created, captured, or managed by the Organisation during its course of operation. It includes data used for planning, managing, operating, or auditing an administrative function of the organisation.

Metadata is structured data that describes and/or enables finding, managing, controlling, understanding or preserving other information over time. Metadata includes, but is not restricted to, characteristics such as the content, context, structure, access, and availability of the data.

Personally Identifiable Information (PII) is data contained in Organisation systems that is private information as defined by the Privacy Act.

Primary source means the official Organisation record for the relevant data.

Record means information, in its original form or otherwise, including (without limitation) documents, signatures, seals, text, images, sound, speech, or data created, received and/or maintained by, or on behalf of, Massey Organisation in the conduct of its affairs. Records can be compiled, recorded or stored in written form on any material, including film, negative, tape, or any other reproducible medium, or by means of recording devices, computers or any other electronic device or process which makes them machine-readable.

Structured Data is data that resides in a fixed field or file e.g. data contained in databases and spreadsheets. This data is often generated during business transactions and is stored in a business information system e.g. student data which is stored in a student management system (SMS) or financial data which is stored in a financial management system (TechnologyOne).

Unstructured Data is data that does not have a pre-defined data structure that is easily readable by machines e.g. audio, video and unstructured text. Unstructured data may have structured elements e.g. metadata associated with an email, xml document.


All XIMNET staff and its affiliated organisations, including its business enterprises such as wholly owned subsidiary companies, joint venture companies, partnerships, trusts and research centres.
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