Leadline Inc.Leadline Inc.
Control Requirements

DS-06: Data Classification Policy

Annual review and update of data classification policy with comprehensive handling procedures

Control Description

On an annual basis, the Company's data classification policy, is reviewed, updated, and approved by management and outlines the handling, communication, destruction, maintenance, storage, back-up, distribution, identification, and classification of confidential information, as well as the identification of related processes, systems, and third parties involved in the handling of such information. If the classification of the data is not defined, the default data classification is confidential.

Plain Meaning

This control requires organizations to have a comprehensive data classification policy that is reviewed and updated annually by management. The policy must cover all aspects of data handling including storage, backup, distribution, and destruction, with a default classification of "confidential" for undefined data.

Implementation

Data Classification Framework

Classification Levels

  • Public: Information that can be freely shared
  • Internal: Company information for internal use only
  • Confidential: Sensitive business information
  • Restricted: Highly sensitive data (PII, PHI, financial)

Default Classification

  • All undefined data defaults to "Confidential"
  • Regular review of unclassified data
  • Automated classification where possible

2. Data Classification Policy Template

Policy Structure

# Data Classification Policy

## 1. Purpose and Scope
This policy defines how data is classified, handled, and protected within the organization.

## 2. Data Classification Levels

### Public Data
- Marketing materials
- Public announcements
- General company information
- Handling: No special protection required

### Internal Data
- Employee communications
- Internal reports
- Project documentation
- Handling: Internal access only, basic protection

### Confidential Data
- Business plans
- Financial data
- Customer information
- Handling: Encrypted storage, access controls

### Restricted Data
- PII (Personal Identifiable Information)
- PHI (Protected Health Information)
- Financial records
- Passwords and credentials
- Handling: Maximum protection, strict access controls

## 3. Data Handling Procedures

### Storage
- Public: Standard file systems
- Internal: Encrypted storage
- Confidential: Encrypted storage with access logs
- Restricted: Encrypted storage with audit trails

### Backup
- Public: Standard backup procedures
- Internal: Encrypted backups
- Confidential: Encrypted backups with retention policies
- Restricted: Encrypted backups with strict retention

### Distribution
- Public: No restrictions
- Internal: Internal network only
- Confidential: Encrypted transmission required
- Restricted: Secure channels only

### Destruction
- Public: Standard deletion
- Internal: Secure deletion
- Confidential: Secure deletion with verification
- Restricted: Certified destruction

## 4. Roles and Responsibilities
- Data Owners: Define classification
- Data Custodians: Implement protection
- Users: Follow handling procedures
- Management: Annual review and approval

## 5. Review and Updates
- Annual review by management
- Updates as business needs change
- Training for all employees

Key Success Factors

  1. Comprehensive Policy: Cover all aspects of data handling
  2. Annual Review: Regular review and management approval
  3. Default Classification: All undefined data defaults to confidential
  4. Automation: Automated classification and handling where possible
  5. Documentation: Clear procedures for each classification level

Common Pitfalls to Avoid

  • No Annual Review: Policy becomes outdated
  • No Default: Undefined data has no classification
  • Incomplete Coverage: Not covering all handling aspects
  • No Automation: Manual classification is error-prone
  • BDR-06: Data retention and destruction
  • BDR-07: Data retention and destruction standards
  • DS-05: Physical media disposal and DLP

Policy Resources

Classification Tools

Compliance Resources