Roles/responsibilities: owners, controllers, processors, custodians/stewards

5.1 Security governance

📘CompTIA Security+ (SY0-701)


In IT security governance, every piece of data, system, or application has people responsible for it. Knowing these roles ensures accountability, compliance, and proper protection of data. The main roles are:


1. Data Owners

Who they are:

  • The person or group who has the legal authority or responsibility for a piece of data or an IT asset.

Key responsibilities:

  • Decide who can access the data.
  • Determine the classification of data (like public, internal, confidential, or restricted).
  • Approve security policies for their data.

IT example:

  • A database administrator (DBA) may own the customer database. They decide that only sales and support staff can access customer records.
  • Another example: The HR manager owns employee records and decides who can see payroll information.

2. Data Controllers

Who they are:

  • The person or organization that determines why and how data is processed.

Key responsibilities:

  • Set rules on how data is collected, stored, and used.
  • Ensure compliance with regulations like GDPR or HIPAA.

IT example:

  • A cloud service provider may store user data but the client company is the controller—they decide the purpose of storing it (e.g., marketing analysis).
  • In an HR system, HR decides which employee data will be processed and for what purpose (payroll, performance review, etc.).

3. Data Processors

Who they are:

  • The person or organization that processes data on behalf of the controller. They do not own or control the data, just manage it according to instructions.

Key responsibilities:

  • Follow the controller’s instructions.
  • Ensure data is protected during processing.
  • Maintain records of data processing activities.

IT example:

  • A cloud hosting company running an application for a client processes data but doesn’t decide its use.
  • An IT outsourcing company managing payroll software for HR is a processor—they process the data but HR is the controller.

4. Custodians / Stewards

Who they are:

  • Individuals or teams responsible for the day-to-day maintenance and protection of data.

Key responsibilities:

  • Implement and manage security controls.
  • Perform backups, patching, and access control.
  • Ensure data integrity and availability.

IT example:

  • IT staff who manage servers and apply security patches to databases.
  • System administrators who monitor network access logs to ensure only authorized personnel access systems.

Summary Table for Easy Exam Recall

RoleResponsibilityIT Example
OwnerOwns the data, decides access and classificationHR manager deciding who can view payroll records
ControllerDetermines how and why data is usedHR sets rules for processing employee data
ProcessorProcesses data as instructedIT outsourcing firm managing payroll software
Custodian/StewardMaintains and protects dataSystem admin performing backups and patching

Important Exam Tips

  1. Owner ≠ Controller ≠ Processor – Know the difference:
    • Owner = decides who owns it and who can access it
    • Controller = decides why and how data is used
    • Processor = follows instructions to handle data
    • Custodian = keeps data safe and maintained
  2. Think about the flow of responsibility in IT systems: Ownership → Control → Processing → Custody.
  3. Regulatory frameworks like GDPR often test your knowledge of controllers vs processors, so focus on that distinction.

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