Chief Information Governance Officer (CIGO) - Revision history

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User at 21:25, 4 October 2021

2021-10-04T21:25:11Z

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User at 20:49, 4 October 2021

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User at 20:36, 4 October 2021

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 == See Also ==
 *[[Leadership]]
 *[[IT Governance]]
-*[[Information Governance (IG)]]
 == References ==
 <references/>

@@ Line 1: / Line 1: @@
 == Definition of Chief Information Governance Officer ==
-The '''Chief Information Governance Officer (CIGO)''' is a senior role to establish and maintain an enterprise-wide culture for an accountable and business-focused [[information management]] environment. The CIGO:
+The '''Chief Information Governance Officer (CIGO)''' is a senior role to establish and maintain an enterprise-wide culture for an accountable and business-focused [[Information Management]] environment. The CIGO:
 *champions the value of information assets and their effective management at an organizational level
 *establishes an organizational culture that encourages and supports staff to manage and use information assets strategically

@@ Line 150: / Line 150: @@
 *[[Chief Operating Officer (COO)]]
 *[[Chief Procurement Officer (CPO)]]
 *[[Chief Technology Officer (CTO)]]

@@ Line 1: / Line 1: @@
 == Definition of Chief Information Governance Officer ==
-The '''Chief Information Governance Officer (CIGO)''' is a senior role to establish and maintain an enterprise-wide culture for an accountable and business-focused [[Information Management|information management]] environment. The CIGO:
+The '''Chief Information Governance Officer (CIGO)''' is a senior role to establish and maintain an enterprise-wide culture for an accountable and business-focused [[information management]] environment. The CIGO:
 *champions the value of information assets and their effective management at an organizational level
-*establishes an [[Organizational Culture|organizational culture]] that encourages and supports staff to manage and use information assets strategically
+*establishes an organizational culture that encourages and supports staff to manage and use information assets strategically
-*drives [[Digital Innovation|digital innovation]] and capability in information management
+*drives digital innovation and capability in information management
 *delivers expert and up-to-date advice on overarching information management strategy
-*leads information governance across the agency, including engaging with information and data managers and users to support [[Best Practice|best practices]] for information management.<ref>What is Chief Information Governance Officer (CIGO)? [https://www.naa.gov.au/information-management/information-governance/establishing-information-governance-framework/chief-information-governance-officer-cigo naa.gov.au]</ref>
+*leads information governance across the agency, including engaging with information and data managers and users to support best practices for information management.<ref>What is Chief Information Governance Officer (CIGO)? [https://www.naa.gov.au/information-management/information-governance/establishing-information-governance-framework/chief-information-governance-officer-cigo naa.gov.au]</ref>
-Today, there is endless talk about [[Data|data]]. [[Big Data|Big data]], smart data, data, data, data. But there is much information about data being utilized as an asset. Digital Information and data are not exactly the same. And if data, aka digital information, begins to take on the form of an asset, watch out. Assets are carried on the balance sheet. Digital information assets could be worth millions, or tens of millions, or hundreds of millions of dollars on the balance sheet in the upcoming decade.
+Today, there is endless talk about data. Big data, smart data, data, data, data. But there is much information about data being utilized as an asset. Digital Information and data are not exactly the same. And if data, aka digital information, begins to take on the form of an asset, watch out. Assets are carried on the balance sheet. Digital information assets could be worth millions, or tens of millions, or hundreds of millions of dollars on the balance sheet in the upcoming decade.
@@ Line 16: / Line 16: @@
 There have been multiple conversations over the recent months where senior corporate executives have begun to speak about data as digital information and an asset, leading to the establishment of the role Chief Information Governance Officer within their organizations.
-Effective [[Information Governance (IG)|information governance]] is so important that it has become a [[C-Suite|C-suite]] role in many [[Organization|organizations]], with an executive responsible for its implementation. The Chief Information Governance Officer (CIGO) often oversees the initial governance initiative, shepherding its development, management and ongoing evolution throughout the organization. The officer is generally responsible for maintenance of information integrity standards, gathering required quality and usage metrics and ensuring that the company meets compliance and regulatory requirements.<ref>Defining Chief Information Governance Officer (CIGO) [https://searchcompliance.techtarget.com/definition/information-governance Techtarget]</ref>
+Effective information governance is so important that it has become a [[C-Suite|C-suite]] role in many organizations, with an executive responsible for its implementation. The Chief Information Governance Officer (CIGO) often oversees the initial governance initiative, shepherding its development, management and ongoing evolution throughout the organization. The officer is generally responsible for maintenance of information integrity standards, gathering required quality and usage metrics and ensuring that the company meets compliance and regulatory requirements.<ref>Defining Chief Information Governance Officer (CIGO) [https://searchcompliance.techtarget.com/definition/information-governance Techtarget]</ref>
@@ Line 65: / Line 65: @@
 == The CIGO Role: A Maturity Framework<ref>A Maturity Framework for the CIGO Role [https://iginitiative.com/wp-content/uploads/IGI-CIGO-Task-Force-Report-Low-Res.pdf IG Initiative]</ref> ==
-In the [[Information Governance Initiative (IGI)|IGI’s]] 2014—2015 Annual Report, we advocated elevating information governance (IG) to the C-suite with the creation of the CIGO role because, for IG to be effective, some entity within the organization must be empowered to coordinate and act. Their first Task Force was asked to build on this idea and to explore in more detail what the CIGO role would look like at an organization. With an eye toward creating a sample CIGO job description. the group moved from just the creation of a sample job description to developing a model describing the CIGO’s role at varying levels of IG maturity. The chart below outlines the responsibilities that a CIGO would have at the three maturity levels. A more detailed description of the IG maturity levels as well as the CIGO’s responsibilities at each level follows. The framework can also be thought of as both descriptive and prescriptive—showing what a CIGO might do day-to-day at each level or showing what a CIGO would
+In the [[Information Governance Initiative (IGI)|IGI’s]] 2014—2015 Annual Report, we advocated elevating information governance (IG) to the C-suite with the creation of the CIGO role because, for IG to be effective, some entity within the organization must be empowered to coordinate and act. Their first Task Force was asked to build on this idea and to explore in more detail what the CIGO role would look like at an organization. With an eye toward creating a sample CIGO job description. the group moved from just the creation of a sample job description to develop a model describing the CIGO’s role at varying levels of IG maturity. The chart below outlines the responsibilities that a CIGO would have at the three maturity levels. A more detailed description of the IG maturity levels as well as the CIGO’s responsibilities at each level follows. The framework can also be thought of as both descriptive and prescriptive—showing what a CIGO might do day-to-day at each level or showing what a CIGO would
 need to do to take an organization to the next level.
@@ Line 133: / Line 133: @@
 == See Also ==
-[[C-Suite]]<br />
+*[[Leadership]]
-[[Leadership]]<br />
+*[[IT Strategy (Information Technology Strategy)|IT Strategy]]
-[[Business Strategy]]<br />
+*[[E-Strategy]]
-[[IT_Strategy_(Information_Technology_Strategy)|IT Strategy]]<br />
+*[[IT Governance]]
-[[E-Strategy|e-Strategy]]<br />
+*[[Information Governance (IG)]]
-[[IT Governance]]<br />
+*[[Information Management]]
-[[Information Governance (IG)]]<br />
+*[[IT Management (Information Technology Management)]]
-[[Information Management]]<br />
+*[[Enterprise Architecture]]
-[[IT Management (Information Technology Management)]]<br />
+*[[IT Sourcing (Information Technology Sourcing)]]IT Sourcing]]
-[[Enterprise Architecture]]<br />
+*[[IT Operations_(Information_Technology_Operations)|IT Operations]]
-[[IT_Sourcing_(Information_Technology_Sourcing)|IT Sourcing]]<br />
+*[[Business IT Alignment]]
-[[IT Operations_(Information_Technology_Operations)|IT Operations]]<br />
+*[[Chief Executive Officer (CEO)]]
-[[Business IT Alignment]]<br />
+*[[Chief Digital Officer (CDO)]]
-[[Chief Executive Officer (CEO)]]<br />
+*[[Chief Financial Officer (CFO)]]
-[[Chief Digital Officer (CDO)]]<br />
+*[[Chief Innovation Officer]]
-[[Chief Financial Officer (CFO)]]<br />
+*[[Chief Operating Officer (COO)]]
-[[Chief Innovation Officer]]<br />
+*[[Chief Procurement Officer (CPO)]]
-[[Chief Operating Officer (COO)]]<br />
+*[[Chief Risk Officer (CRO)]]
-[[Chief Procurement Officer (CPO)]]<br />
+*[[Chief Technology Officer (CTO)]]
 == References ==
 <references/>

← Older revision		Revision as of 21:25, 4 October 2021
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−	== The CIGO Role in Law Firms [https://www.ironmountain.com/resources/general-articles/t/the-cigo-role-in-law-firms Iron Mountain]</ref> ==	+	== The CIGO Role in Law Firms<ref>The CIGO Role in Law Firms [https://www.ironmountain.com/resources/general-articles/t/the-cigo-role-in-law-firms Iron Mountain]</ref> ==
	There is a noteworthy difference of opinion among law firm management regarding the chief information governance officer (CIGO) role and to whom the responsibilities of this position best belong. Many technologists believe information governance best fits the job description of chief information officers (CIOs) because of their technical acumen; others think the role is best suited to chief financial officers (CFOs) because of their responsibilities regarding risk management and financial liability.		There is a noteworthy difference of opinion among law firm management regarding the chief information governance officer (CIGO) role and to whom the responsibilities of this position best belong. Many technologists believe information governance best fits the job description of chief information officers (CIOs) because of their technical acumen; others think the role is best suited to chief financial officers (CFOs) because of their responsibilities regarding risk management and financial liability.

@@ Line 6: / Line 6: @@
 *delivers expert and up-to-date advice on overarching information management strategy
 *leads information governance across the agency, including engaging with information and data managers and users to support [[Best Practice|best practices]] for information management.<ref>What is Chief Information Governance Officer (CIGO)? [https://www.naa.gov.au/information-management/information-governance/establishing-information-governance-framework/chief-information-governance-officer-cigo naa.gov.au]</ref>
 Effective [[Information Governance (IG)|information governance]] is so important that it has become a [[C-Suite|C-suite]] role in many [[Organization|organizations]], with an executive responsible for its implementation. The Chief Information Governance Officer (CIGO) often oversees the initial governance initiative, shepherding its development, management and ongoing evolution throughout the organization. The officer is generally responsible for maintenance of information integrity standards, gathering required quality and usage metrics and ensuring that the company meets compliance and regulatory requirements.<ref>Defining Chief Information Governance Officer (CIGO) [https://searchcompliance.techtarget.com/definition/information-governance Techtarget]</ref>
@@ Line 105: / Line 114: @@
 *Consults regularly with all levels of legal management to ensure that handling of information assets meets the company’s legal, regulatory, and ethical obligations.
 *Business intelligence, privacy, records and information management (HIM), and knowledge management teams are direct reports to the CIGO.

@@ Line 1: / Line 1: @@
-Effective [[Information Governance (IG)|information governance]] is so important that it has become a [[C-Suite|C-suite]] role in many [[Organization|organizations]], with an executive responsible for its implementation. The '''Chief Information Governance Officer (CIGO)''' often oversees the initial governance initiative, shepherding its development, management and ongoing evolution throughout the organization. The officer is generally responsible for maintenance of information integrity standards, gathering required quality and usage metrics and ensuring that the company meets compliance and regulatory requirements.<ref>Defining Chief Information Governance Officer (CIGO) [https://searchcompliance.techtarget.com/definition/information-governance Techtarget]</ref>
+== Definition of Chief Information Governance Officer ==
-'''CIGO Responsibilities<ref>CIGO Responsibilities [https://www.naa.gov.au/information-management/information-governance/establishing-information-governance-framework/chief-information-governance-officer-cigo National Archives of Australia]</ref>'''<br />
 A CIGO’s core responsibilities can be divided into four categories: leadership, strategy, technical and engagement.
 *Leadership
@@ Line 36: / Line 55: @@
-'''The CIGO Role: A Maturity Framework<ref>A Maturity Framework for the CIGO Role [https://iginitiative.com/wp-content/uploads/IGI-CIGO-Task-Force-Report-Low-Res.pdf IG Initiative]</ref>'''<br />
+== The CIGO Role: A Maturity Framework<ref>A Maturity Framework for the CIGO Role [https://iginitiative.com/wp-content/uploads/IGI-CIGO-Task-Force-Report-Low-Res.pdf IG Initiative]</ref> ==
 In the [[Information Governance Initiative (IGI)|IGI’s]] 2014—2015 Annual Report, we advocated elevating information governance (IG) to the C-suite with the creation of the CIGO role because, for IG to be effective, some entity within the organization must be empowered to coordinate and act. Their first Task Force was asked to build on this idea and to explore in more detail what the CIGO role would look like at an organization. With an eye toward creating a sample CIGO job description. the group moved from just the creation of a sample job description to developing a model describing the CIGO’s role at varying levels of IG maturity. The chart below outlines the responsibilities that a CIGO would have at the three maturity levels. A more detailed description of the IG maturity levels as well as the CIGO’s responsibilities at each level follows. The framework can also be thought of as both descriptive and prescriptive—showing what a CIGO might do day-to-day at each level or showing what a CIGO would
 need to do to take an organization to the next level.
-[[File:CIGO Role Maturity Framework.png|400px|CIGO Role Maturity Framework]]<br />
+[[File:CIGO Role Maturity Framework.png|600px|CIGO Role Maturity Framework]]<br />
 source: IGI
-''Level One: Nascent'' <br />
+'''''Level One: Nascent''''' <br />
 *State of IG: At this level the organization has either no or only a nascent IG program. Many or most facets of IG are either missing entirely or are significantly underdeveloped, but basic RIM and IT functions are in place. There is no formal coordination of information-related activities. To the extent that coordination happens, it is largely unplanned and incidental. There is also no formal IG body (e.g. a steering committee, board, etc.) in place to coordinate IG. Basic policies and procedures are in place for paper records, however, those policies and procedures may be old and out of date. They do not extend to non-paper records, though there is an awareness that they should. Basic IT infrastructure (email systems, shared drives, etc.) is in place, but technology is not being used to effectuate the organization’s IG program. There is no to minimal review of compliance with existing policies and procedures. The organization has minimal or no plans in place for incidents (security breaches, discovery, etc.) and responds to them and other IG concerns as issues arise. The organization’s posture is reactive versus proactive.
 *The CIGO’s Role: At this level, the CIGO role would likely not be a standalone position. It would sit within one of the other facets of IG and be “shepherded” through its development. The CIGO’s primary role would be building the foundation for IG. The CIGO would:
@@ Line 56: / Line 75: @@
 **Begin building known risks into standard policies and procedures, where possible, to routinize response to them.
-''Level Two: Intermediate''<br />
+'''''Level Two: Intermediate'''''<br />
 *State of IG: At this level the organization has an established but still developing IG program. The CIGO is emerging as a quasi-independent role, but may still be tied closely to one of the other facets of IG. Many facets of IG are in place and reasonably well developed. Some roles need to be filled and some existing facets must mature. A senior IT professional (CIO/CTO) focused on infrastructure and possibly information security (CISO) are in place. Planned coordination of some information-related activities is occurring, but it is not comprehensive over all facets of IG or on all projects. There is a formal IG body that meets occasionally. Policies and procedures have been reviewed and updated and are being extended to non-paper information, but coverage is incomplete. Comprehensive, organization-wide policies and procedures are not yet in place. Some basic technologies are being used for IG. More advanced and comprehensive approaches are being considered. Some compliance monitoring is in place, but the coverage is spotty. The organization is in a reactive posture with respect to some types of incidents but has begun to take a proactive posture with respect to the types of crises it has addressed in the past.
 *The CIGO’s Role At this level, the CIGO role would likely still be closely tied to one of the other facets of IG. However, the CIGO would be emerging as a separate and distinct function. The CIGO’s primary role would be building the framework and structure of an effective IG program. The CIGO would:
@@ Line 67: / Line 86: @@
 **Continue to expand the organization’s incident readiness. Ensure that all regular or anticipated events (e-discovery, investigations, employee departures, etc.) are built into processes, so they are not disrupters of routine.
-''Level Three: Advanced''<br />
+'''''Level Three: Advanced'''''<br />
 *State of IG: At this level the organization has a well-developed or advanced IG program. The CIGO is in a top level position, independent of a particular facet of IG and is a co-equal to other top information positions (CIO/CTO, CISO, etc.). The major facets of IG are in place and are well developed. There is formal, comprehensive coordination of information-related activities. The coordination is part of a formal plan that seeks to maximize the value of information while minimizing risk. There is a formal IG body in place to coordinate IG. It communicates and meets regularly. Comprehensive, organization-wide IG policies and procedures are in place and extend to all types of information regardless of format. They are being reviewed and updated as appropriate. As appropriate, technology is being used to implement IG. Some processes are likely automated. A formal auditing procedure is in place and being executed regularly. The organization has procedures in place to avoid incidents (like breaches) where possible and also to respond to others (e.g. litigation or investigations) as part of the regular IG process.
 *The CIGO’s Role: At this level the CIGO would be a standalone entity and co-equal to other high level roles like the CIO/CTO and CISO. The CIGO’s primary role would be maintaining and improving the existing IG program with an eye toward optimizing the organization’s use of its information. The CIGO would:
@@ Line 79: / Line 98: @@
-'''CIGO Key Relationships<ref>CIGO Key Relationships [https://bok.ahima.org/doc?oid=301367#.YVtTTprMLIU Ahima]'''</ref><br />
+== CIGO Key Relationships<ref>CIGO Key Relationships [https://bok.ahima.org/doc?oid=301367#.YVtTTprMLIU Ahima]</ref> ==
 *Reports to the CEO.
 *Collaborates as a peer with the CIO and CISO with each having primary but overlapping areas of influence corresponding to IT infrastructure, information itself, and information security for the CTO, CIGO, and CISO, respectively.

@@ Line 36: / Line 36: @@
-'''The CIGO Role: A Maturity Framework<ref>A Maturity Framework for the CIGO Role [https://iginitiative.com/wp-content/uploads/IGI-CIGO-Task-Force-Report-Low-Res.pdf IG Initiative]</ref'''><br />
+'''The CIGO Role: A Maturity Framework<ref>A Maturity Framework for the CIGO Role [https://iginitiative.com/wp-content/uploads/IGI-CIGO-Task-Force-Report-Low-Res.pdf IG Initiative]</ref>'''<br />
 In the [[Information Governance Initiative (IGI)|IGI’s]] 2014—2015 Annual Report, we advocated elevating information governance (IG) to the C-suite with the creation of the CIGO role because, for IG to be effective, some entity within the organization must be empowered to coordinate and act. Their first Task Force was asked to build on this idea and to explore in more detail what the CIGO role would look like at an organization. With an eye toward creating a sample CIGO job description. the group moved from just the creation of a sample job description to developing a model describing the CIGO’s role at varying levels of IG maturity. The chart below outlines the responsibilities that a CIGO would have at the three maturity levels. A more detailed description of the IG maturity levels as well as the CIGO’s responsibilities at each level follows. The framework can also be thought of as both descriptive and prescriptive—showing what a CIGO might do day-to-day at each level or showing what a CIGO would
 need to do to take an organization to the next level.
@@ Line 77: / Line 77: @@
 **Conduct regular, formal auditing of all policies and procedures. Automate auditing functions where possible.
 **Maintain and improve the organization’s incident readiness. Expand focus on value-generating processes.

← Older revision		Revision as of 20:36, 4 October 2021
Line 34:		Line 34:
	**Inform whole-of-government initiatives		**Inform whole-of-government initiatives
	**Influence information and data legislation and policy		**Influence information and data legislation and policy
		+
		+
		+	'''The CIGO Role: A Maturity Framework<ref>A Maturity Framework for the CIGO Role [https://iginitiative.com/wp-content/uploads/IGI-CIGO-Task-Force-Report-Low-Res.pdf IG Initiative]</ref'''><br />
		+	In the [[Information Governance Initiative (IGI)\|IGI’s]] 2014—2015 Annual Report, we advocated elevating information governance (IG) to the C-suite with the creation of the CIGO role because, for IG to be effective, some entity within the organization must be empowered to coordinate and act. Their first Task Force was asked to build on this idea and to explore in more detail what the CIGO role would look like at an organization. With an eye toward creating a sample CIGO job description. the group moved from just the creation of a sample job description to developing a model describing the CIGO’s role at varying levels of IG maturity. The chart below outlines the responsibilities that a CIGO would have at the three maturity levels. A more detailed description of the IG maturity levels as well as the CIGO’s responsibilities at each level follows. The framework can also be thought of as both descriptive and prescriptive—showing what a CIGO might do day-to-day at each level or showing what a CIGO would
		+	need to do to take an organization to the next level.
		+
		+
		+	[[File:CIGO Role Maturity Framework.pngFile.png\|400px\|CIGO Role Maturity Framework.png]]<br />
		+	source: IGI
		+
		+
		+	''Level One: Nascent'' <br />
		+	*State of IG: At this level the organization has either no or only a nascent IG program. Many or most facets of IG are either missing entirely or are significantly underdeveloped, but basic RIM and IT functions are in place. There is no formal coordination of information-related activities. To the extent that coordination happens, it is largely unplanned and incidental. There is also no formal IG body (e.g. a steering committee, board, etc.) in place to coordinate IG. Basic policies and procedures are in place for paper records, however, those policies and procedures may be old and out of date. They do not extend to non-paper records, though there is an awareness that they should. Basic IT infrastructure (email systems, shared drives, etc.) is in place, but technology is not being used to effectuate the organization’s IG program. There is no to minimal review of compliance with existing policies and procedures. The organization has minimal or no plans in place for incidents (security breaches, discovery, etc.) and responds to them and other IG concerns as issues arise. The organization’s posture is reactive versus proactive.
		+	*The CIGO’s Role: At this level, the CIGO role would likely not be a standalone position. It would sit within one of the other facets of IG and be “shepherded” through its development. The CIGO’s primary role would be building the foundation for IG. The CIGO would:
		+	**Identify missing or underdeveloped key facets of IG and begin building out or developing these roles.
		+	**Begin building alliances and working relationships between the facets of IG and coordinating projects across facets.
		+	**Create an informal working group, leveraging emerging alliances.
		+	**Review and revise existing policies and procedures, expanding them, incrementally, to cover more types of information and more uses.
		+	**Assess current IT infrastructure, including understanding where and how information is being stored and determining the specific needs of the organization to know what technological solutions would add value.
		+	**Develop an employee education program on existing policies and procedures, and about IG.
		+	**Begin building known risks into standard policies and procedures, where possible, to routinize response to them.
		+
		+	''Level Two: Intermediate''<br />
		+	*State of IG: At this level the organization has an established but still developing IG program. The CIGO is emerging as a quasi-independent role, but may still be tied closely to one of the other facets of IG. Many facets of IG are in place and reasonably well developed. Some roles need to be filled and some existing facets must mature. A senior IT professional (CIO/CTO) focused on infrastructure and possibly information security (CISO) are in place. Planned coordination of some information-related activities is occurring, but it is not comprehensive over all facets of IG or on all projects. There is a formal IG body that meets occasionally. Policies and procedures have been reviewed and updated and are being extended to non-paper information, but coverage is incomplete. Comprehensive, organization-wide policies and procedures are not yet in place. Some basic technologies are being used for IG. More advanced and comprehensive approaches are being considered. Some compliance monitoring is in place, but the coverage is spotty. The organization is in a reactive posture with respect to some types of incidents but has begun to take a proactive posture with respect to the types of crises it has addressed in the past.
		+	*The CIGO’s Role At this level, the CIGO role would likely still be closely tied to one of the other facets of IG. However, the CIGO would be emerging as a separate and distinct function. The CIGO’s primary role would be building the framework and structure of an effective IG program. The CIGO would:
		+	**Continue to shore up existing facets and build out any that are missing to create a comprehensive approach to information and begin assuming a leadership role with respect to primarily information-focused facets of IG.
		+	**Leverage existing alliances to have IG issues considered from the very beginning of projects. Facilitate the inclusion of other necessary facets in the planning process to encourage active coordination across information-related activities.
		+	**Lead the existing IG body. Ensure that all facets are represented. Encourage regular and frequent meetings where the various facets can actively plan coordination on new and existing projects.
		+	**Review and revise policies and procedures to cover information regardless of format. Expand and integrate policies across the organization as warranted.
		+	**Identify and implement/expand technological solutions to facilitate consistent application of IG policies and procedures.
		+	**Expand educational programs on policies and procedures. Audit compliance on critical regulatory or legal requirements and expand to audit other information activities.
		+	**Continue to expand the organization’s incident readiness. Ensure that all regular or anticipated events (e-discovery, investigations, employee departures, etc.) are built into processes, so they are not disrupters of routine.
		+
		+	Level Three: Advanced
		+	State of IG At this level the organization has a well-developed or advanced IG program. The CIGO is in a top level position,