For Insurance Firms

Data Controls That Hold Up
Under Scrutiny

Most insurance firms have a Data Control Framework. Most would not withstand a serious audit. The Provenance Method gives you genuine, auditable assurance over your critical data flows — not the appearance of it.

Free Guide
The Provenance Method

A practical guide to building data control frameworks that perform under regulatory and audit scrutiny. From flow mapping to residual risk — the full methodology.

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Controls were in place. They didn't catch the issue. Here is why.

The failure is rarely a shortage of controls. It is a failure of precise risk articulation — and it is baked in at the design stage. Three recurring reasons explain why experienced teams with well-maintained frameworks still get caught out.

01
Vague Risk Statements

Risk statements written by governance teams rather than subject matter experts result in language that fails to describe risk at a level that is actionable. Vague risks produce generic controls. Generic controls produce the illusion of assurance.

02
Misaligned Incentives

Precise risk articulation creates accountability. Vagueness — consciously or not — provides cover. Frameworks built from the inside rarely surface the exposures that matter most, because surfacing them is uncomfortable.

03
Retrofitting

Many frameworks are built around the controls that already exist rather than the risks that actually matter. The result looks complete on paper but leaves material exposures unaddressed — in precisely the places that get you in front of a regulator.

A control framework that tells you what you already wanted to hear is not providing assurance.
It is providing reassurance — and reassurance is considerably less useful when something goes wrong.

From data flow to genuine assurance — a structured methodology

Step 01 — Map
Understand the Complete Journey

The correct starting point is not the risk register. It is the data — specifically, a precise map of how data is created and actually moves through your organisation.

  • Start at the use case, not the source
  • Trace horizontal and vertical lineage
  • Surface shadow processes and manual interventions
  • Document existing controls at each step
Step 02 — Assess
Identify and Evaluate Risk

Once the data flow is accurately mapped, inherent risks become visible in a way they cannot be from a high-level process description. Precision here is not optional.

  • Identify specific failure modes, not categories
  • Assess likelihood and impact against the actual flow
  • Evaluate existing control effectiveness objectively
  • Establish residual risk against appetite
Step 03 — Control
Build Proportionate Assurance

When a risk is articulated precisely, the appropriate control often becomes self-evident. It follows logically from an honest description of what could go wrong.

  • Design preventative and detective controls in concert
  • Balance primary and compensating controls
  • Write unambiguous, auditable control narratives
  • Ensure the framework is risk-proportionate
The Outcome
Assurance that is proactive, auditable and genuinely proportionate to the risks your organisation faces — performing under regulatory and audit scrutiny at the moments when it matters most.

Built for the people responsible when something goes wrong

Chief Data Officers

Responsible for the quality and integrity of critical data, but working with frameworks that were built before the current regulatory environment. The Provenance Method gives you a defensible, auditable foundation.

Risk and Compliance Directors

Facing regulatory reviews where the gap between a control that exists and a control that works becomes acutely visible. You need a residual risk position you can actually defend — not one that reflects optimism.

Heads of Actuarial and Finance

Whose outputs — capital models, regulatory returns, financial statements — are only as reliable as the data flowing into them. A framework built on the Provenance Method gives you traceability from use case back to source.

Internal Audit and Second Line

Charged with providing independent assurance over data controls — but finding that the frameworks you are asked to assess were not built with auditability in mind. We design frameworks that give second and third line something real to work with.

Built from the inside of the industry, not from a distance

Provenance Data Risk Partners was founded by Navin Ahuja, a specialist in data quality assurance for the insurance sector with direct experience designing and auditing data control frameworks across major insurance firms.

The Provenance Method was developed from that experience — from the recurring gap between frameworks that looked adequate and frameworks that actually held up when tested.

Designed data control frameworks within the Lloyd's and London market
Audited Chief Data functions at major insurance carriers
Deep expertise in Solvency II, regulatory data quality and model governance

"The most dangerous position is not knowing your framework is inadequate. It is believing it is adequate — and finding out otherwise during a regulatory review."

A discovery call takes 30 minutes. It gives you an honest, independent assessment of where your framework stands and where the most material gaps are likely to lie.

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Is your Data Control Framework
truly fit for purpose?

Start with the guide. Understand the methodology. Then let's have an honest conversation about where your framework stands.

No obligation. No sales pitch. Just clarity from someone who has built and audited these frameworks from the inside.