From Data Cleanup to Ongoing Third-Party Data Governance

Sector :

Financial Services

The Challenge

A major Canadian financial services organization recognized the responsibility it held for personal identifiable information (PII) managed by third-party vendors and, seeing peers impacted by data mismanagement, sought to establish a clear, accountable system for its proper handling. While internal data cleanup efforts were underway, the company recognized that unmanaged vendor-held data, particularly dormant or excess records, posed potential for significant privacy, compliance, and reputational risk.

Our Approach

Juno Risk was engaged in designing and implementing a structured third-party data treatment and deletion approach. This included defining the vendor outreach process, prioritization criteria, acceptable evidence of data deletion, and a quality-based evidence rating model. The engagement established clear expectations for vendors, created defensible audit trails, and enabled consistent oversight of third-party data handling practices.

Outcome

Following the success of this initiative, Juno Risk was re-engaged to help operationalize a durable, enterprise-wide data treatment governance capability. Building on recent investments in data cleanup initiatives and Archer GRC tooling, Juno Risk supported the transition from one-time remediation to a sustainable program model. This included governance structures, management planning, integration with privacy, procurement, cyber, and compliance functions, and ongoing oversight mechanisms. The result was a scalable, repeatable Data Treatment Program that protects sensitive information, maximizes return on prior investments, and supports long-term regulatory compliance.