# Data Roles*

  • Data ownership is based on possession.
  • Data type is based on data format.
  • Data context refers to the environment in which the data resides and is manipulated.
  • Data jurisdiction refers to the standardizing bodies and regulatory entities that control the data.
  • Data Owner
  • Data Controller
  • Data Processor
  • Data Custodian

# Data Owner

The entity that holds the legal rights and control over a set of data. Data owners define distribution and associated policies.

In most cases, this is the organization that has collected or created the data. This is also the individual with rights and responsibilities for that data; this is usually the department head or business unit manager for the office that has created or collected a certain dataset.

# Data Controller

The person who either alone or jointly with other persons determines the purposes for which and the manner in which any personal data is processed; this entity determines the "why" and "how" personal data is processed.

# Data Custodian

Data custodians are responsible for the safe custody, transport, data storage, and implementation of business rules. This is any organization or person who manipulates, stores, or moves the data on behalf of the data owner.

The custodian is usually a specific entity in charge of maintaining and securing the privacy-related data on a daily basis, as an element of the data's use; for example, this could be a database administrator hired by the CSP.

The data custodian must adhere to any policies set forth by the data owner in regard to the use of the data.

# Data Processor

Any person other than the data owner who processes the data on behalf of the data owner/controller.

# Data Steward

The person responsible for data content, context, and associated business rules.

While the data owner maintains sole responsibility for the data and the controls surrounding that data, there is sometimes the additional role of data steward, who will oversee data access requests and the utilization of the data.

# Data Subject

The individual who is the focus of personal data.