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For me, this question is like looking at two different angles of a prism.  Both sides admit that the digital transformation of the enterprise (of ANY size) means that the digital assets of the business require closer attention, and the infrastructure to do business is critical.

But for me, the Chief Digital Officer is more of a focus on the processes of the organisation, and the Chief Data Officer is more of a focus on the precious assets of the business.

I am an information economist by training, so I go back to the Theory of the Firm, in which all elements are contracted relationships — except for the firm’s data.  The data is the critical asset that in context belongs to the firm and its processes, and its usage and management are a key function of how a firm makes money, utilises resources and maximises profit.

Is the organisation looking to leverage its assets in more productive ways?  Or is the organisation trying to streamline how business is done, not only for more marketing automation, but for a richer and deeper relationship with the customer?

Two-sides of the same coin, which is why the terms CMO and CIO have morphed into CDO, for which many do not agree with what it means.

Just my humble opinion.  😉