Data Classification Policy

1. Purpose

The purpose of this policy is to establish a framework for classifying data based on its sensitivity, value and criticality to the organization, so sensitive corporate and customer data can be secured appropriately.

2. Scope

This policy applies to any form of data, including paper documents and digital data stored on any type of media. It applies to all of the organization’s employees, as well as to third-party agents authorized to access the data.

3. Roles and Responsibilities

Data owner — The person who is ultimately responsible for the data and information being collected and maintained by his or her department or division, usually a member of senior management. The data owner shall address the following:

Data custodians — Technicians from the IT department or, in larger organizations, the Information Security office. Data custodians are responsible for maintaining and backing up the systems, databases and servers that store the organization’s data. In addition, this role is responsible for the technical deployment of all of the rules set forth by data owners and for ensuring that the rules applied within systems are working. Some specific data custodian responsibilities include:

Data user — Person, organization or entity that interacts with, accesses, uses or updates data for the purpose of performing a task authorized by the data owner. Data users must use data in a manner consistent with the purpose intended, and comply with this policy and all policies applicable to data use.

4. Data Classification Procedure

  1. Data owners review and assign each piece of data they own an information type based on the categories in NIST 800-600 Volume 1.

  2. Data owners assign each piece of data a potential impact level for each of the security objectives (confidentiality, integrity, availability), using the guide in Section 6 of this document. The highest of the three is the overall impact level.

  3. Data owners assign each piece of data a classification label based on the overall impact level:

    Overall impact level Classification label
    High Restricted
    Moderate Confidential
    Low Public
  4. Data owners record the impact level and classification label for each piece of data in the data classification table.

  5. Data custodians apply information security controls to each piece of data according to its classification label and overall impact level.

5. Impact Level Determination

Use this table to assess the potential impact to the company of a loss of the confidentiality, integrity or availability of a data asset that does not fall into any of the information types described in Section 5 and NIST 800-600 Volume 2.

Security Objective Potential Impact
Low Moderate High
Confidentiality. Restrict access to and disclosure of data to authorized users in order to protect personal privacy and secure proprietary information. Unauthorized disclosure of the information is expected to have limited adverse effects on operations, organizational assets, or individuals. Unauthorized disclosure of the information is expected to have a serious adverse effect on operations, organizational assets, or individuals. Unauthorized disclosure of the information is expected to have a severe or catastrophic adverse effect on operations, organizational assets, or individuals.
Integrity. Guard against improper modification or destruction of data, which includes ensuring information nonrepudiation and authenticity. Unauthorized modification or destruction of the information is expected to have a limited adverse effect on operations, assets, or individuals. Unauthorized modification or destruction of the information is expected to have a serious adverse effect on operations, assets, or individuals. Unauthorized modification or destruction of the information is expected to have a severe or catastrophic adverse effect on operations, assets, or individuals.
Availability. Ensure timely and reliable access to and use of information. Disruption of access to or use of the information or information system is expected to have a limited adverse effect on operations, assets, or individuals. Disruption of access to or use of the information or information system is expected to have a serious adverse effect on operations, assets, or individuals. Disruption of access to or use of the information or information system is expected to have a severe or catastrophic adverse effect on operations, assets, or individuals.

7. Appendix A

Types of Information that Must be Classified as “Restricted”

Authentication information

Authentication information is data used to prove the identity of an individual, system or service. Examples include:

Electronic Protected Health Information (ePHI)

ePHI is defined as any protected health information (PHI) that is stored in or transmitted by electronic media. Electronic media includes computer hard drives as well as removable or transportable media, such as a magnetic tape or disk, optical disk, or digital memory card.

Transmission is the movement or exchange of information in electronic form. Transmission media includes the internet, an extranet, leased lines, dial-up lines, private networks, and the physical movement of removable or transportable electronic storage media.

Payment Card Information (PCI)

Payment card information is defined as a credit card number in combination with one or more of the following data elements:

Personally Identifiable Information (PII)

PII is defined as a person’s first name or first initial and last name in combination with one or more of the following data elements: