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ING Group’s Information Audit and Policy Development

Executive Summary

This document gives a short summary of ING’s business and how this business is affected by the information that the company must process on a daily basis. The document further stresses the need for this information for the proper functioning of the company and need to have the information regulated. Once ING’s information needs are well understood, the document proposes an information policy which is best suited for the organization. The information policy suggested includes a policy statement which is aligned with the company’s mission and strategy. Finally, this document proposes an implementation strategy which would take care of the risks associated with the policy and seek to ensure a smooth implementation.

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The purpose of this report is to identify the information needs of a huge financial conglomerate like ING and based on these needs propose an information policy which is aligned with the company’s mission and strategy. Before the suggestion of an information policy, it is necessary to understand the workings of the organization. To this end, ING is thoroughly researched with the help of information regarding the company available in the public domain. The sources of this information include the various websites and web pages of the company. ING’s annual report for the year 2008 is one of the main sources of information utilized in this report.

Information management is extremely important for the proper functioning of any organization. It becomes even more important for an organization the size of ING. However, an information management system needs a well implemented information policy in order to be successful. Information policy ensures that people who need the information have access to it at the right time, they are not overwhelmed by it and information is not misused. To this end, information policy plays the role of monitoring the Information management system.

This report tries its best to be as comprehensive as possible. However, it has to work under several limitations. The report is based only on the information about ING which is available in the public domain. Information about many of the internal functions of the organization was not available and had to be assumed in order to develop this report.

The Organization

ING is a global financial institution, with headquarters in Amsterdam, Netherlands, “offering banking, investment, life insurance and retirement services”. The group has over 85 million private, corporate and institutional customers spread across the globe. The Group today employs about 115,000 employees worldwide, with the majority in Europe. ING offers a vast range of financial products to meet all kinds of customer demands through the six business lines of Retail Banking, Wholesale Banking, ING Direct, Insurance Asia/Pacific, Insurance Europe and Insurance Americas. Each of these business lines report to the executive board

ING mission statement as mentioned on their global site is “to set the standard in helping our customers manage their financial future”. However, since ING has a wide range of businesses operating all over the globe, each of the businesses may have their own mission statement. For example, the Lease department of the whole sale banking site in Hungary gives its mission statement as “To be accepted in our chosen markets as the leading, trusted and reliable business partner able to offer innovative solutions which exceed the evolving needs of our customers”.

For a dynamic business such as financial services, the strategy must be updated regularly to reflect the current economic and business realities. This is reflected in the company’s latest strategy which hopes to earn and maintain customer trust by strategizing for the short term, medium term as well as long term. In the short term they hope to strengthen their financial position, in the medium term the hope is to stabilize the company and reinforce their credibility and in long term they promise to maximize business opportunities while maintaining the financial health and growth of the company.

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The key business of ING revolves around taking care of customer finances throughout their lives. As a result, ING’s business strategy is focused towards long-term profits. This means ING must keep detailed and accurate information about all their customers in order to be able to serve them well over their lifetime. They must also diligently invest customer funds to give them the best returns and earn their trust. In short, ING’s core business is about managing customer funds so as to be able to give them best returns over long term.

It is apparent from ING annual report that the company is focused on information management. They repeatedly mention their focus on putting the customer first. Considering that they have over 85 million customers, this is not possible without having a strong information management policy and a highly structured information system in place. The well planned organizational strategy shows that the company is in sync with all the internal and external contingencies and believes in planning ahead to mitigate risks.

A high level audit of the information resources that ING needs in order to carry out its functions shows that ING’s information policy is well aligned with various environmental factors. The 2008 annual report details a growth strategy based on the current recessional economy. The report also shows the company has carried out detailed analysis of all the markets in which it operates and has identified that various growth opportunities in each of these markets. For example, in case of Americas, they are focused on the “long term growth opportunities presented by the ageing of the US population and the increasing wealth in Latin America” (Annual Report). They also have a diversified product range to suit the income and demography of the countries they operate in.

Coming to the company’s handling of Human Resource, the company has a very positive policy in place which maximizes employee engagement in the running of the company and retains talent by getting the best people in the right places (annual report). This means, that ING hires people who have the best skill sets, knowledge and expertise. The adoption of technology in the recruitment process with the aim to share information also points to the company’s information centric approach. Thus ING has a well established need for information in all its functions.

Introducing an Information Policy

ING is a huge company with over 85 million customers, 115,000 employees, six business lines and businesses all over the globe. Managing such a huge organization effectively means that certain systems need to be in place and have to be adhered to by all the employees if the organization hopes to remain competitive. An information system without a proper information policy in place runs the risk of going out of control and hence not being effective.

It is usually assumed that only the senior management need information for carrying out their responsibilities properly. A well formulated information policy addresses all the stakeholders and not just the senior management. According to Middleton (2002), the role of information policy is not to support decision making but to provide a framework decision making. An information policy can be implemented only with a high degree of help and support of the senior management.

ING’s main business is in banking and insurance. Both these businesses involve handling of huge sums of money on behalf of the client. As mentioned on ING’s site and annual report, in order to be successful, ING needs to be customer-centric and win customer trust. This is only possible if the customer is convinced that his information and funds are safe with ING. The company has to routinely acquire and store client related information on their system. This sensitive information can result in huge losses if the information is leaked. Hence, the organization needs to have a comprehensive privacy policy in place to ensure that client related information does not get leaked or misused. Since ING is handling customer funds, customers may want to know how these funds are being invested. Hence, it becomes ING’s responsibility to convey information related to trading and trading policies to their clients. However, releasing such information on a daily basis could be overwhelming, both for the clients as well as ING. So a policy needs to be in place to govern the time and frequency at which this information is made available to the clients and other stakeholders. Also, ING has a number of insurance and investment related products which need to be communicated to the clients. This too requires a policy on how and in what form this product related information is shared with the clients. Thus, in order to become more client focused, the company needs to have several information related policies in place. Since managing customer funds is the core business of ING, an information policy to ensure proper customer service becomes a must for the company.

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In order to be able to carry out their responsibilities, the senior management needs to be aware of the various environmental factors affecting their business. These factors may be either internal or external. Without a proper information policy, this information could reach the managers in a haphazardly way and may result in the managers becoming inundated by information overload. An information policy would ensure that the information management system in place is properly utilized and is cost-effective in ensuring smooth flow of business processes.

The human resources in any organization also need access to information in order to function properly. The MIS system can provide this information, but there needs to be a policy to ensure that the right people get the right information. An organization like ING, which handles sensitive customer information, needs to have an information policy which ensures that sensitive information does not fall in wrong hands. Finally, employees need to be made aware of latest company policies regarding work, promotions, ethics, social responsibility and a host of other issues. This is only possible if there is a well defined information policy to which all employees have access.

A well defined and properly executed information policy ensures that the MIS system in the organization functions effectively. It also minimizes information overload. It helps co-ordinate the different type of information available to an organization. An information policy is also useful in ensuring that information is not misused and right information is disseminated at the right time to the right people within and outside the organization. The information policy addresses all the stakeholders of an organization.

The main disadvantage of having an information policy is that it needs constant monitoring to ensure that it is not being violated. This can increase the budget of the MIS. Also, the information policy needs to be updated regularly to take into account the changing environments.

Information Policy

An organization generates huge amounts of information internally and acquires even bigger amounts of information from external sources (InfoPro Resource Center). As the size of an organization increases, so does the amount of information which must be handled on a daily basis. A properly implemented information policy will ensure that this information is handled properly, it is not misused and the executives are not overwhelmed by an information overload. For an organization the size of ING, a properly implemented information policy becomes even more important to ensure proper functioning of all is business units.

An information Policy cannot be implemented without the support of the senior management. However, it is the information professionals who must implement the policy. Any information policy implemented in ING will be owned by its Executive Board so that it gets uniformly implemented across all its six business lines. It will be the responsibility of the information professionals at the local level to ensure that the policy endorsed by the Executive Board is actually implemented on a daily basis at the local level.

The information policy for ING would seek to “ensure that the customers and employees have access to all relevant data at all times without compromising security of the information or the privacy of the customers”. This policy is in line with ING’s mission and strategy to focus on customers. Once implemented, the policy would need to be reviewed on a regular basis to keep up with the changing internal and external environments. It is proposed that the policy is reviewed and updated on an annual basis to ensure that it remains up-to-date in view of the fast changing information needs of a company like ING.

Information is the most important resource for a company like ING. In order to properly invest customer funds, the company must have access to a whole range of external and environmental information. This information must be updated regularly, indeed every minute in case of investments in financial markets, to ensure maximum profitability for both ING and its customers. The information policy will outline some of the basic principles to manage these huge amounts of information.

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This policy proposes to identify and evaluate all the internal documents and disseminate it in an orderly fashion. A system must be in place to acquire external content for the organization as a whole and once acquired, it must be properly archived for future use.

The policy must also address security and permission related issues to ensure that people who need the information have access to it and yet sensitive information does not fall in wrong hands. This would require a sophisticated network and system architecture to manage accessibility of the information. Finally, the policy must also address what kind of information is made available to the clients and at what intervals. Since company website is a main source of information for all stakeholders who are external to the company, website publishing standard also needs to be set.

Once this policy has been formulated and passed by the executive board, it needs to be implemented. The information technology professional are in the best position to implement the policy. However, they would need the help and inputs from a wide range of user groups including Marketing, Customer Service, Human Resource and legal department. ING would also need a department to shift through all the external information and pick the once which are critical for the proper functioning of the firm. Once all this internal and external information is available to the information technology professional, they must publish this content with proper checks and security permissions.


ING’s main business is managing the finances of its clients spread all over the world. This is an especially sensitive business since clients need to have complete trust in the organization if they are to hand over their hard earned money to the company. In order to gain this trust ING must have all the relevant information related to client funds easily available at all times. Yet, considering the sensitive nature of this information, adequate steps must be taken to ensure that the information does not get leaked or is misused. This is only possible if there is a well formulated and properly implemented information policy in place.

This document attempts to understand the information needs of a huge company like ING and based on the publicly available information attempts to propose an information policy which would be in keeping with the requirements of their business objective. The information policy suggested is only a model, however, a similar but more comprehensive information policy and its proper implementation is a must for any organization in today’s information age if it hopes to remain competitive.


2008. Annual Report. ING. Web.

Creating Corporate Information Policy. (2009). Dow Jones Infopro Resource Center. [online] Web.

Middleton, M.R. (2002). Information Management: a consolidation of operations, analysis and strategy. Wagga Wagga, Center of Information Studies.

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