How to Make a Data Map: Risk Management, Compliance and Governance

Why Data Management Matters

Data is often called “the new oil.” It’s valuable, powers our digital revolution, and depends on refinement. Additionally, like fossil fuel, data requires care in collection, storage, transportation, and utilization because every step presents a risk of breach.

That’s why effective data management is so crucial.

• What data is your company collecting?
• Where is it being stored?
• Who can access it?
• And what’s the plan for it all?

Shockingly, few companies spend appropriate amounts of time refining their data management strategies. But in a world driven by data, this should be a top priority.

In this article, I will walk you through how to build a Data Map from start to finish.

About the Author

My name is Liz Benegas; I serve as a General Counsel to companies at various stages of growth—from early stage to post-acquisition and IPO readiness. Part of my daily work is to help company leadership tackle compliance challenges. I identify potential points of risk and guide companies through proven steps to prevent that risk.  

One of my most powerful tools is a data map, and in this guide, I will walk you through exactly how you can build one for yourself.

What is a data map?

Data mapping is the process of creating data element mappings between two distinct data models. It ensures data consistency and integrity across different systems, facilitating accurate data transfer, integration, and analysis. The data map is the end result of that process. It can take many forms (for example, I use a simple Google Sheet). 

Why build a data map?

With the rise of SaaS apps and shadow IT, the likelihood of data breaches is on the rise, and increasing regulatory scrutiny means those breaches become more impactful both monetarily and reputationally. 

In this environment, control over your data is critical. This is one reason a data map is an important piece of an effective data management program.  A data map shows what data your organization has, where that data flows, and who handles it, so you can spot vulnerabilities to help your company ensure compliance and mitigate risks. It also offers quick wins like spotlighting redundant apps or users and helping your company establish third-party risk processes. In the long term, it helps manage data, streamline processes, and boost IT leadership—which is essential for staying secure and compliant.

How to build a data map

Step 1: Establish a Source of Truth (SSOT)

A successful data map starts with a reliable, centralized source of truth. Choose a system for capturing your data—whether it’s a spreadsheet, diagram, or specialized tool—and stick to it. You’ll need to list all categories of data your organization processes, such as customer, employee, or financial data. The best place to start is with your apps. Remember, shadow IT can be a blind spot, so use tools like Torii to uncover unapproved apps. Keep in mind that your data map will only be as effective as the accuracy of the information it contains, so start with a clear structure.

Step 2: Conduct In-Depth Stakeholder Interviews

Your data map is only as strong as the information you gather from the people who work with the data every day. Organize interviews with department heads to understand how they use applications, what kind of data they process, and how data is shared. Pay close attention to unused and redundant apps during these interviews—they represent a cost-saving opportunity. Keep in mind that this step can be tedious but is crucial for building a comprehensive map. The more thorough you are here, the better your data map will reflect your organization’s true data landscape.

Step 3: Identify Third Parties and Subprocessors

Data often leaves your organization’s control, so it’s important to know and track which vendors are handling it. Make a list of all third-party vendors your data interacts with, paying special attention to those dealing with sensitive data or personal information. This is critical for compliance with regulations like GDPR, which has strict requirements regarding subprocessors (third parties that handle personal data on behalf of your customers or clients). Don’t just stop at identifying third parties—make sure to assess their security controls and ensure they meet required standards. Keep in mind that each vendor or subprocessor may require different regulatory due diligence.

Step 4: Compile and Analyze Data

Once you have gathered data from various sources, it’s time to pull it all together and assess it for potential risks and opportunities. Aggregate all the information you’ve collected from stakeholder interviews, SOC 2 reports, and vendor lists into one comprehensive view. Look for patterns or issues such as redundant tools, data silos, or potential security vulnerabilities. Identifying these pain points is where the real value of the data map comes in—don’t rush this step. Keep in mind that this is your opportunity to eliminate inefficiencies and shore up your security and privacy processes.

Step 5: Conduct a Risk Assessment and Prioritize

Risk is everywhere in data management, so prioritizing the biggest threats is key. Assess the risks associated with your data, focusing on the highest priorities like sensitive customer information. Once the risks are categorized, develop a plan for addressing them. Remember that not all data is created equal—some types of data (like health or financial information) may require stronger controls than others. Keep in mind that prioritization helps your organization focus its efforts where they will have the most impact.

Step 6: Craft and Implement Policies

With risks identified, it’s time to create policies to protect your data. Policies should address everything from data protection and retention to third-party risk management and deletion practices. Ensure that these policies are tailored to the specific needs of your organization and the data types you handle. Don’t forget that policies should be living documents—revisit them regularly to keep them aligned with the evolving data landscape and changes in your business practices. Keep in mind that a solid set of policies will act as a roadmap for your data management strategy.

Step 7: Maintain and Update the Data Map

A data map isn’t a “set it and forget it” document—it needs to be maintained and updated to remain accurate. Schedule regular reviews, ideally quarterly, to ensure all new applications, tools, and data sources are captured. Keep engaging with departments to understand any changes in how they use applications or handle data. Remember, accuracy over time is what will make your data map a valuable asset, so keep it dynamic and reflective of your organization’s real-time data practices.

Step 8: Present and Socialize the Data Map

Once your data map is created, you’ll need to communicate its value across the organization. Build a strong business case highlighting cost savings, compliance improvements, and risk mitigation benefits. Share quick wins, such as reduced application costs or immediate security improvements, to demonstrate the value of the map early on. Don’t forget to engage influencers in different departments—cross-departmental support will make or break your project’s success. Keep in mind that this step is crucial for getting buy-in and ensuring your data map becomes a tool that others use, not just a siloed project.

Step 9: Establish Long-Term Management and Compliance

Data maps help your organization stay compliant and secure in the long run. Integrate your data map into your broader security frameworks, ensuring it’s a central part of your risk management strategy. Schedule ongoing compliance checks using the data map as your foundation for audits and assessments. Collaboration between IT, security, and compliance teams will keep your data protected and aligned with regulations. Keep in mind that the strength of your data map will show its true value when it’s used to proactively prevent risks and meet regulatory demands.

Conclusion

Creating a data map might seem like a big undertaking, but it’s one of the most valuable steps you can take to protect your business and streamline your operations. Think of it as building a blueprint for your data—one that helps you see exactly where everything is, who’s handling it, and where potential risks might be hiding. It’s not just about staying compliant with regulations; it’s about finding opportunities to cut costs, improve security, and make smarter decisions. 

Start small and keep it manageable—your data map doesn’t need to be perfect right away. As long as it’s a living document that you update regularly, it will become a powerful tool that supports your business goals and keeps you ahead of the curve.