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Under King V, data governance is a board accountability issue—not just a technology-team report. The Code was released on 31 October 2025 and applies to financial years beginning on or after 1 January 2026; early adoption is encouraged, according to the IoDSA. In its interpretation of Principle 10, Ascent Technology argues that boards need evidence of what sensitive data the organisation holds, who can access it, whether the systems storing it remain supported, and how suppliers handle it.
What does King V Principle 10 mean for the board?
IoDSA describes King V as a principles-based governance code. Ascent’s reading of Principle 10 is that the governing body is accountable for effective, compliant and ethical management and control of data and information across its acquisition, use, dissemination and disposal. That is Ascent’s interpretation of the board’s practical responsibility, not a substitute for the Code’s exact wording or legal advice.
The change in emphasis is consequential: a policy, delegated committee mandate or annual-report paragraph may document governance arrangements, but it does not by itself show that the organisation knows where sensitive data is, who can reach it, or whether the systems and providers involved are appropriately managed. Ascent frames the board’s task as asking for operational evidence, not simply accepting that a policy exists.
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What should directors be able to ask and verify?
Ascent’s operational test can be put in four direct questions:
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- Where does the sensitive data sit? The organisation should be able to identify and classify the data it considers sensitive, and map where it is held.
- Who holds standing access to it? Access should be attributable to people, roles and providers, with periodic review and sign-off rather than an assumption that old permissions remain appropriate.
- Which of the engines holding it are still supported? A data map is incomplete if it does not also identify the database or other system holding the data and track that system’s support status.
- Who else touches this data? The view should include suppliers and outsourced providers, not just the organisation’s own staff and infrastructure.
These questions are a practical interpretation of Principle 10, not an official IoDSA checklist. Their value is that they turn an abstract governance responsibility into evidence the board can request and challenge.
What counts as evidence rather than paperwork?
Ascent recommends assessing the substance and currency of governance records. Directors can ask management to show whether the following are complete, current and subject to review:
- A data inventory that identifies and classifies sensitive information and records where it resides.
- An access review that identifies standing access, its scope and the person responsible for approving it.
- A record of support status for systems holding sensitive data, with a process for tracking changes.
- Supplier and outsourced-provider coverage showing which third parties handle the data and how their involvement is accounted for.
- Periodic assurance, including relevant activity evidence and tested recovery arrangements.
These are implementation measures drawn from Ascent’s recommendations, not a complete set of requirements issued by IoDSA. The useful board-level distinction is whether management can produce current, reviewable evidence for the organisation’s actual systems and relationships—not merely point to a policy or committee structure.
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Repair Windows errors before they cause bigger problemsFix Now →Scan for outdated or missing drivers - takes under a minuteDriver Scan →How can the board choose implementation support?
IoDSA identifies two support routes. Which is appropriate depends on membership eligibility and whether the need is informal orientation or organisation-specific formal advice.
| Option | Best suited to | What to know |
|---|---|---|
| Member technical support | IoDSA members seeking informal, high-level King V guidance. | Member-only support; IoDSA says it is not legal advice and does not constitute a formal opinion. |
| Paid advisory services | Organisations seeking formal opinions or advice tailored to a specific implementation question. | A paid service offered by IoDSA; scope and terms should be confirmed directly with the Institute. |
These options are described by IoDSA. Informal technical support and paid advisory serve different needs; neither should be confused with the board’s responsibility to oversee the organisation’s own data governance.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What King V dates should organisations use?
IoDSA states that King V was released on 31 October 2025 and is effective for financial years beginning on or after 1 January 2026. Early adoption is encouraged. Applicability therefore turns on the start date of the organisation’s financial year, rather than simply the calendar date on which a board first discusses the Code. Check the official King V page for the Code and current materials.
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