Data stewardship best practices for regulatory compliance

In many organizations, data governance exists on paper, but data stewardship is where things actually break or hold together.

With GDPR already enforced, the EU Data Act coming into force, and the EU AI Act on the horizon, many companies are discovering a hard truth:
having a governance framework is not the same as being governed.

Governance, ownership, and stewardship are not the same thing

One of the most common sources of confusion, and risk, is the way these roles are blurred.

Data governance sets the rules

Data governance defines:

• what data may be collected

• how it may be used

• under which legal and ethical constraints

• how decisions are documented and escalated

Governance answers the question:
“What are the rules of the game?”

Data owners are accountable for specific assets

A data owner is accountable for a defined data asset or domain.

That means:

• understanding what the data represents

• knowing how it is used

• ensuring it follows governance rules

Ownership is often mistaken for control. In reality, ownership is accountability, not sovereignty.

Data stewards make governance real

Data stewardship sits between rules and reality.

A data steward:

• sees across domains, not just one system

• checks whether governance is applied consistently

• identifies downstream impact of local changes

• investigates issues without blame

• ensures traceability and transparency

Stewardship answers the question:
“Do our rules actually work in practice?”

Without stewardship, governance remains theoretical.

The biggest stewardship mistake: no internal authority

The most damaging pattern I see is this:

Data stewards are appointed, but not empowered.

They exist on paper, but:

• cannot access all relevant data

• cannot challenge data owners

• cannot block or escalate risky changes

• are treated as advisors rather than guardians

This fails especially in large organizations, where each data owner sees only their local system.

A steward’s value is precisely that they see cross-system and downstream effects.

When stewardship has no procedural authority, governance fragments.

What regulators and auditors actually look for

Contrary to popular fear, regulators are not looking for perfection.

They look for accountability and traceability.

In practice, this means:

• Can you explain who decided what, and why?

• Can you show how a change was made?

• Can you trace data from source to use?

• Can you demonstrate that mistakes are detected and corrected?

Trying to hide mistakes is far riskier than admitting and documenting them.

Strong stewardship creates evidence as a byproduct of doing the work.

Why stewardship matters more under the EU Data Act

The EU Data Act shifts attention toward:

• data access rights

• downstream reuse

• interoperability

• contractual and technical constraints

This dramatically increases the risk of local changes with global impact.

A governance-compliant change in one system, for example an ERP or SAP instance, can still:

• break downstream analytics

• violate access assumptions

• affect data shared externally

Data stewards are the only role positioned to spot this early, because they operate above individual systems and egos.

Non-negotiables for effective data stewardship

Across organizations and industries, a few principles consistently matter.

Neutrality over control

Stewards must not be embedded in delivery teams in a way that compromises independence.

Their role is not to defend past decisions, but to surface issues.

Auditability by default

Unique accounts, change logs, timestamps, and traceable transformations are non-negotiable.

If a change cannot be traced, it cannot be defended.

Quality over ego

Stewardship only works when:

• blame is irrelevant

• fixing the issue matters more than saving face

• data quality and compliance trump local authority

When data owners see themselves as the final authority, governance collapses.

Escalation without politics

Stewards must be able to:

• raise concerns

• escalate unresolved risks

• document dissent

Even when business decisions override stewardship advice, that disagreement must be visible and justified.

Stewardship as the translator between rules and reality

Data governance defines intent.
Data stewardship tests whether that intent survives contact with real systems.

Without stewards who understand both:

• regulatory expectations, and

• technical and operational realities

governance becomes a document archive, not a control system.

A practical first step

If you are unsure whether stewardship works in your organization, start small.

Pick one critical metric or dataset and trace:

• ownership

• transformations

• access

• retention

• downstream usage

If the thread breaks, stewardship is missing or underpowered.

How we help

We support organizations with:

• governance and compliance assessments

• stewardship role design and empowerment

• informal audits aligned with GDPR, the EU Data Act, and future AI regulation

• translating governance frameworks into operational reality

If this sounds familiar, you can book a discovery call or request an informal governance assessment to identify the highest-risk gaps before they turn into incidents.

How We Can Help

Our Audits & Compliance Assessments help organizations verify compliance, reduce uncertainty, and move forward with confidence.