More and more data is being collected on all aspects of banking operations, yet collectively, the totality of ‘data issues’ are still not properly aggregated nor, more importantly, understood by management. This publication looks at the Basel 239 Principles and the underlying challenges of risk data aggregation. However, this issue has to be based on a much broader perspective than simply that of risk data. BCBS 239 may be the prime driver at the moment. But the data challenge demands a much broader strategic response.