Please see the attached PDF (from the International Federation of Health Information Management Associations) and seek other sources if you wish to answer the following questions – the PDF will help answer the questions.

please view “Data Governance Vs. Information Governance”, a seminar by a consulting firm from July 2021

1.What are the drivers (needs, reasons for) of information governance (IG) and data governance (DG)? 
2.  How do the differences between these drivers frame the different purposes and functions between information governance and DG?
3. Are information governance and DG the same thing, at odds with each other, or complementary? Explain and defend your answer.
4. What are possible synergies between information governance and DG?

Revisiting Information


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the advancement of health information management practices and the
development of its members for the purpose of improving health data and
health outcomes.

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Revisiting Information

Healthcare Transformation Requires
Trusted Information ………………………………………………….3

The Importance of Information Governance ………………..4

Information Governance as Stewardship …………………….5

Stewardship Foundations …………………………………………..5

Governance as Ground Rules and Guardrails ……………….6

IG Framework to Ensure Success ……………………………….6

IG and Health Information Management Practice ………..6

Trigger Events …………………………………………………………..7

IG Learnings from Global Experiences ………………………..7

It’s Time to Start ………………………………………………………8

Conclusion ……………………………………………………………….8

Revisiting Information Governance | October 2021


In 2017, the International Federation of Health
Information Management Associations (IFHIMA)
published a whitepaper with case studies –
Advancing Health Information Governance: A
Global Imperative. The paper offered details
regarding the pressing need for information
governance (IG) with consideration for
transformation in the delivery of health services
brought on by the digitization of data, new
regulations and more.

Then in 2020 COVID-19 shook the world,
especially the world of healthcare. The

disease spread so quickly that even the
experts seemed to be at a loss and

overwhelmed. This crisis forced the
use of technologies that were

formerly on the fringe.
Healthcare at a distance,
telehealth, became
routine. Reliance on
artificial intelligence
and consumer driven
tools, i.e., smartphone
and apps proliferated
in professional and
personal settings. At
many institutions,
health information
professionals (HIMs)
moved to remote

settings to continue their
work while taking on new roles

and responsibilities. These conditions
and the continuation of transformation of health
service in nations around the world, have made
IG even more challenging and important. That’s
why IFHIMA is revisiting this important and
timely topic.

Healthcare Transformation
Requires Trusted Information

Local and national health services, irrespective
of the maturity of their systems and data use,
are redesigning care delivery and public and
private health services by embracing 21st
century solutions. Redesign is supporting the
shift from illness-based care to wellness. These
priorities involve greater engagement and
inclusion by patients, families, and communities
and have refined approaches to information
access, information sharing, funding, and

reimbursement. Layered on these trends is the
evolving information demands resulting from the
COVID-19 pandemic.

Information is a strategic asset, much like
physical assets – buildings, equipment, and
technology – and is the essential tool for
transformation. “Organizations that encourage
staff to think about information and data as a
strategic asset can extract more value from
their systems.”1 Systems mean both technology
and operational processes. Every healthcare
organization needs to optimize its systems – in
other words, optimize its information and data
created or used from its various systems.

In all circumstances, information must
be trustworthy to meet the demands and
strategic transformational goals of healthcare
organizations, their consumers/patients, and
governmental and non-governmental agencies.

Health providers continue to transition
from paper-based to digital health systems.
Developing nations are especially focusing
on this transition through an initial launch
of digital systems or when they are using a
hybrid approach to meet their goals. The hybrid
approach may be a combination of electronic,
imaged, and paper records. A myriad of
approaches is evident in both mature health
environments and developing nations. These
systems support personal wellness and care;
care delivery systems; local, national, and global
public health disease prevention, identification,
and tracking; and information policy
development and improvement initiatives. The
COVID-19 pandemic further demonstrates the
need to create, link, and share data supporting
individual, national and global health.

Digital health information requires focused
management and governance – stewardship
– to address new challenges and risks. Thus,
stewardship through governance requires data
quality and integrity, data access, reporting,
data integration, confidentiality and security,
patient and provider identity management and
lifecycle management. (Stewardship is explored
in IFHIMA’s 2020 whitepaper, Privacy of Health
Information, an IFHIMA Global Perspective.)

Regardless of where organizations or nations
reside on the technology adoption and data
standardization spectrum, it is never too soon
for a ministry of health, a health department, a
large healthcare enterprise, a small ambulatory

Information is a strategic
asset, much like physical

assets – buildings,
equipment, and technology

– and is the essential tool for

Revisiting Information Governance | October 2021


or primary care clinic or payer organization
to incorporate governance and stewardship

Information governance (IG) provides the
authority mechanism that sets forth principles
and policies and approves procedures and
technology for how an organization will
exercise its stewardship responsibilities. Most
importantly, a strong IG program serves the
needs of the consumer, patient, and citizen.

The Importance of Information

The importance and goal of healthcare
transformation is well summarized in this
statement that describes the role of the World
Health Organization (WHO): “To improve equity
in health, reduce health risks, promote healthy
lifestyles and settings, and respond to the
underlying determinants of health.”2

The building blocks supporting these goals
are health records – records of patients’

health status, treatment, and social
determinants of health

(SDOH); and vital
records – birth and
death records.

Health care organizations
are learning that they
need to formalize IG.
According to Health
IT Analytics, “In a
survey released by
AHIMA at the 89th
Annual Exhibit &
Convention, 53 percent
of respondents said
they have information
governance programs
in place or recognize
the need for one. A
scant 14 percent have
initiated organization-
wide IG programs, but
18 percent have some

form of governance activity

The importance of information in transforming
healthcare cannot be overstated. From

electronic health records to smart phone apps
to patient portals to telehealth, information is
driving healthcare decisions at all levels as never
before. For example, the use of telehealth as
a viable care delivery and management option
has grown exponentially during the COVID-19
pandemic. “During the first quarter of 2020, the
number of telehealth visits increased by 50%,
compared with the same period in 2019, with
a 154% increase in visits noted in Surveillance
Week 13 in 2020, compared with the same
period in 2019.”4 With that rapid deployment,
often without advance planning or adequate risk
assessments, came the challenges of network
infrastructure, documentation requirements,
data sharing, and privacy and security. In the
IFHIMA article, Managing Health Information
Privacy During the COVID-19 Pandemic:
Considerations and Perspectives from Around
the Globe, released September 24, 2020, we
discussed how the COVID-19 pandemic has
heightened the need for managing the privacy
of information and the urgency for governance
around it.

Data explosion as a driver for IG
Electronic/digital transformation in healthcare
means that the volume of data is growing
exponentially. “IDC (International Data
Corporation) predicts that our global datasphere
– the digital data we create, capture, replicate
and consume – will grow from approximately 40
zettabytes of data in 2019 to 175 zettabytes in
2025 (with one zettabyte equaling one trillion
gigabytes).”5 Further, “human and machine-
generated data is experiencing an overall 10x
faster growth rate than traditional business data,
and machine data is increasing even more rapidly
at 50x the growth rate.”6 This growth is due to
the growing number of devices, sensors, and
the increasing use of artificial intelligence (AI)
and machine learning (ML). As cloud computing
becomes mainstream, data lakes and data
warehouses are being created to accommodate
the data explosion. Precision medicine in some
countries is defining exact treatments and drugs
through intelligence derived from genomics
and the research and analysis of vast stores of
structured and unstructured data. With this uptick
in data growth comes the need to harness it for
its business value, and, likewise, to determine
what is redundant, obsolete, or trivial (ROT) data,
and ultimately, information.

Information governance
(IG) provides the authority
mechanism that sets forth

principles and policies
and approves procedures
and technology for how

an organization will
exercise its stewardship


Revisiting Information Governance | October 2021


Data Governance: a key IG component
While healthcare may be lagging other industries
in establishing formalized IG programs, some
organizations have elected to focus first on data

governance (DG). DG is an essential dimension
of a comprehensive IG program

due to the increasing data
volume and diverse
use. DG is focused on
the data used across
key applications and
processes (i.e., master
data and metadata),
as well as tools used
in managing data (i.e.,
data dictionaries,
data glossaries, data
integration and data
mapping). DG activities
may include addressing
patient or provider

identifiers, master data and
metadata management, data mapping,

data dictionaries, and data standardization.
DG efforts identify data that is useful and
data that is redundant, obsolete, or trivial and
work to address the appropriate disposition of
ROT data. Creating high quality, trusted data
across an organization is the goal of DG and is
a critical dimension of IG. Data governance is
like information governance in that it requires
formalization around its activities. A DG program
should report to IG and take strategic direction
from the IG program. It is critical that the
goals of DG and IG are aligned and support an
organization’s strategic objectives.

By contrast, the whole patient record, including
narrative content, and the policies that

drive its use, retention and
privacy are all within
the purview of IG.
It is reasonable for
healthcare organizations
to focus first on getting
the data right through
DG, because error is
costly, and trust may
be jeopardized. The
emergence of electronic
health record (EHR)

related errors results
in data being lost or incorrectly

entered, displayed, or transmitted, leading
to loss of information integrity.7 Without solid
DG, one cannot have information integrity.

Information Governance as

Effective stewardship of health information
is an important obligation for all who create,
use, or manage information. “Stewardship is
an ethic relating to the responsible handling
of information; and governance sets forth the
ground rules for execution of this responsibility.”8

Preserving confidentiality is an indisputable
stewardship obligation when the subject of
the information is identifiable. This obligation
remains true when patient or provider identifiers
have been removed from a data set for research
and other purposes. (See whitepaper, Privacy
of Health Information, an IFHIMA Global

Stewardship Foundations

The Principles of Fair Information Practice
(FIPPs) and the Caldicott Principles offer policy
makers around the world guidance in crafting
stewardship frameworks for governing health
and other sensitive information in physical or
digital form. Several of the FIPPs principles
are highlighted in Figure 1 by the Organization
for Economic Co-operation and Development
(OECD)9 that represents the cooperation of 35
member nations. These nations have adapted
their own laws covering health information with
consideration to local values; they are generally
legislative expression of the FIPP principles.10 11 12

The Caldicott Principles adopted by UK’s
National Health Service (NHS) include eight

key principles shown in Figure 2 that are the
foundation for stewardship practice and can
serve as another important framework in
developing an IG program.

DG is an essential
dimension of a

comprehensive IG program
due to the increasing data
volume and diverse use.

Preserving confidentiality is
an indisputable stewardship

obligation when the subject of
the information is identifiable.

Figure 1

Revisiting Information Governance | October 2021


Caldicott Principles, 2020 Update

Justify the

Every single proposed
use or transfer of
patient identifiable
within or from an
organization should
be clearly defined
and scrutinized,
with continuing uses
regularly reviewed,
by an appropriate

Don’t use patient
unless it is

Patient identifiable
information items
should not be
included unless it
is essential for the
specified purpose(s)
of that flow. The need
for patients to be
identified should be
considered at each
stage of satisfying the

Use the minimum

Where use of
patient identifiable
information is
essential, the
inclusion of each
individual item of
information should
be considered and
justified so that the
minimum amount
of identifiable
information is
transferred or
accessible as is
necessary for a given
function to be carried

Access to patient
should be on a
strict need-to-
know basis

Only those individuals
who need access to
patient identifiable
information should
have access to it,
and they should only
have access to the
information items that
they need to see. This
may mean introducing
access controls or
splitting information
flows where one
information flow
is used for several

Everyone with
access to patient
should be
aware of their

Action should be
taken to ensure
that those handling
patient identifiable
information – both
clinical and non-
clinical staff – are
made fully aware of
their responsibilities
and obligations
to respect patient

Understand and
comply with the

Lead the evaluation of
data quality with focus
on ICD-11 coded
data and develop
appropriate queries to
resolve discrepancies

Every use of
patient identifiable
information must be
lawful. Someone in
each organization
handling patient
information should
be responsible
for ensuring that
the organization
complies with legal

The principles are fully operationalized through
roles and functions outlined in the 2020
Caldicott Guardians Manual.13

With stewardship foundations in place, IG can
function to establish principles and policies, to
assess and measure how well they are working,

Revisiting Information Governance | October 2021


and to identify when they need to be improved
upon based on new learning or new advances.
Illustrating the accepted global importance of
IG, Gartner defines IG as the specification of
decision rights and an accountability framework
to ensure appropriate behavior in the valuation,
creation, storage, use, archiving and deletion
of information. It includes the processes, roles
and policies, standards and metrics that ensure
the effective and efficient use of information in
enabling an organization to achieve its goals.14

Governance as Ground Rules and

IG provides the authority mechanism that sets
forth principles and policies and approves
procedures and technology for how an
organization will exercise its stewardship
responsibilities. Healthcare organizations set
the scope of governance by determining the
types of information that will be governed
and who has the authority to set policies and

oversee their execution. Health information
management (HIM) plays a key

role in IG by participating
in policy formulation
and/or subsequent

From a practical
perspective, IG
considers the lifecycle
of the information
from its creation
and integration
through archiving or
destruction. Illustrating
the importance and
practical application,
the Canadian Health

Information Management
Association (CHIMA) has a special

workgroup focused on IG and managing
the lifecycle of data. IG considers the range of
functions including:

• Information design and collection

• Records and content management

• Access

• Quality and integrity of information.

IG requires a multi-stakeholder approach

supported by senior leaders and anchored in a
formal framework.

IG Framework to Ensure Success

There is no one-size-fits-all framework. The
framework should be established to fit within
the culture of the organization. However, the
key components of a framework that should be
considered are executive sponsorship, strategic
committee structure with key stakeholder
membership and designated leadership,
program charter, organization-wide education
plan, policies and procedures, and metrics
and accountabilities. A key requirement for
a successful IG program is the formalized
infrastructure around it. A formalized framework
ensures that

• The right stakeholders are involved;

• There is a reporting and support hierarchy;

• There are documented goals that are aligned
with the organization’s strategic plan; and

• Metrics are in place to show results of the
program and its activities.

Lastly, an organization must create a culture
that supports a multi-disciplinary approach to
establishing information policy and managing
information as a key asset.

IG and Health Information
Management Practice

Health Information Management (HIM), a
nearly century old profession, has its roots in
monitoring and improving the content of the
health record. HIM focuses on managing the
lifecycle of the record, particularly its protection,
storage, retrieval, and disposition. Information
curation is an important HIM skill with curation
defined as “the act of individuals chartered
with the responsibility to find, contextualize,
and organize information, providing a reliable
context and architecture for the content they
discover and organize.”15 The ability to preserve
information availability, sustain its credibility,
apply the appropriate compliance, and uphold
its integrity are all vital and integral HIM skills.

An organization must create
a culture that supports a

multi-disciplinary approach
to establishing information

policy and managing
information as a key asset.

Revisiting Information Governance | October 2021


The changing landscape of health information
capture and distribution channels is providing
new opportunities in the healthcare ecosystem
to maximize information curation and improve
information value. The HIM profession
faces many challenges in managing the
quality and integrity, lifecycle management
and confidentiality and security of digital
information. While grounded in traditional
practices, the scope, tools, and complexities
of HIM practice in a digital health environment
require new skills, competencies, and changes
in how HIM services are staffed and organized.
HIM professionals are recognized as well-
established resources for clinical recordkeeping
with aptitudes that continue to be sharpened,
expanded, and called upon to institute and
execute IG. Their critical knowledge and skills
can be shared across the entire organization
in managing all types of information – clinical,
financial, human resources, contractual,
legal, and other business information. HIM
professionals possess the requisite information
management knowledge and skills to positively
impact the management of information across
the entire healthcare setting.

To realize the full value of digital information
in transforming healthcare, HIM professionals
worldwide must engage in and lead the charge
to improve information. HIM professionals must:

• Lead efforts to advance IG and information
management practices,

• Ensure governance policies and best practices
are applied, and

• Ensure all types of critical information assets
are included as the information lifecycle is
rolled out.

Trigger Events

Perhaps the most difficult part of developing
and executing an IG program is finding the
trigger event that catapults IG to the forefront.
Thus, it’s critical to identify current day triggers
and build the IG program around those, using
them to align with the organization’s strategic
goals. The ability to quickly address current day
triggers in an expeditious and formalized way
will prove the worth of an IG program.

Clearly the COVID-19 pandemic should be seen
a trigger. The need to move quickly in times of
uncertainty is paramount.

Technology adoption and implementation such
as a new electronic record, a data lake, a data
warehouse, or using artificial intelligence or
machine learning might also be seen as trigger

An IG program that is built with stewardship to
deliver accurate health information will enable
health care organizations to respond in both
ordinary and challenging times.

IG Learnings from Global

IFHIMA is a powerful network of HIM
professionals from around the world, sharing
best practices for IG and the day-to-day
challenges of managing patient information and
other important health information resources.
In the face of health system change and
transformation, this network has never been
more important. Learning from one another
is the surest way to advance at the pace that
change is required today. To support the
understanding of IG practice and value, HIM
practice and knowledge, four international case
summaries have been included as an appendix
in this paper to demonstrate the need for and
value of IG.

The Case Summaries describe the IG journeys
of Alberta Health Services (AHS) in Canada,
Cabrini Health (Cabrini) in Australia, the Hospital
Corporation of America (HCA) headquartered
Tennessee, USA and Grande Ronde Hospital,
Oregon, USA. They are dynamic stories of
change and learning and these snapshots
convey several important lessons that can be
adapted and adopted by other organizations.
The lessons fall into three general categories:
Purposeful Organizing for IG, Careful Priority
Setting, and Adaptation.

Steering committees will have no trouble
identifying complex, priority information
challenges that benefit from improved
governance. However, particularly in the early
years, it is wise to choose governance initiatives
that will have tangible return on the time and
effort invested or that represent a real risk to the

As with all transformative change, there is
usually a trigger that is both a threat and an
opportunity. The Case Summaries make clear

Revisiting Information Governance | October 2021


one other important lesson. Advancing IG
requires a keen awareness of what is happening
throughout the organization.

It’s Time to Start

Information Governance is critical to
ensuring the trustworthiness of a healthcare
organization’s information for patient care

and other business needs. Health
information management

has traditionally
excellence through cost
effective, consistent
practices carried
out by trained HIM
professionals. The time

is now to ensure that your
organization has an IG program to meet

both operational and strategic priorities. But,
where to start? Below are recommended actions
to move governance forward:

• Learn as much as possible about information
governance and data governance concepts
and practices in healthcare. This white paper
is an excellent start.

• Network with HIM peers to discuss best
practices, top priorities, and lessons learned.

• Share your IG and DG knowledge and
expertise with senior leaders and peers,

• Demonstrate how governance practices
can reduce costs, risks, and can increase

• Evaluate how your organization manages
its information and data. Is it managed in
individual departments, business units, and/or
entities? Is it managed with a narrow scope in
mind? Determine if governance practices are
in place, even if in an immature stage.

• Bring forth ideas for where your organization
can begin in evolving current or immature
practices, to mature, optimized procedures
and systems. Look at current processes
around areas such as record retention,
storage, and destruction, seeking
opportunities to improve processes and
reduce costs and risks. Further, identify
areas of inefficiency – areas where there is
redundancy and rework.

• Volunteer to lead the charge! HIM
professionals are fully equipped to be the
expert and take the lead role.


Healthcare always requires trusted information
and with the many factors impacting healthcare
transformation – from transitioning from
illness-based care to wellness care, advances
in the delivery of healthcare, the digitization
of health records, the exponential growth of
data, to the proper sharing of information for
the improvement of health on a global scale –
information governance is needed now more
than ever.

These factors, along with a crisis, such as
a global pandemic, are driving the need to
accelerate the adoption of an IG framework. One
that begins with a commitment from diverse
stakeholders and disciplines across a healthcare

HIM professionals, are natural stewards of
health information. They have an important
contribution to make in the development and
execution of an IG framework. They possess the
requisite knowledge and skills in management
of information across the entire healthcare

Through this whitepaper and the other topics
and articles cited within, IFHIMA encourages
the practice of information governance to realize
its vision of “a healthy world enabled by quality
health information.”

Information governance is
needed now more than ever.

Revisiting Information Governance | October 2021


References and Endnotes
Advancing Health Information Governance: A Global
Imperative, IFHIMA October 2017

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