Despite the substantial investment made to date around `data' and the additional investments needed to meet heightened global standards, firms are failing to develop a coherent understanding of the strategic implications; and are failing to understand the significance of aligning a firms' data strategy with the overall business strategy. 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.