Data Protection and Classification Policy

Overview

This policy establishes standards for identifying, classifying, and safeguarding all company data—whether accessed by human users or non-human identities such as bots, APIs, and service accounts—throughout its lifecycle. The objective is to ensure data confidentiality, integrity, availability, and compliance with legal and regulatory obligations.

Scope

This policy applies to all data created, stored, processed, or transmitted by the company, including data handled by third-party service providers. It covers both human and non-human identities with access to company data.

Definitions

  • Data Classification: The process of categorizing data based on its sensitivity, value, and regulatory requirements (e.g., Public, Internal, Confidential, Restricted).
  • Sensitive Data: Information that, if disclosed, modified, or destroyed without authorization, could cause significant risk to the organization (e.g., PII, PHI, financial records, intellectual property).
  • Data Owner: Individual or team responsible for data accuracy, classification, and access decisions.
  • Data Steward: Person responsible for enforcing data handling and protection controls for a given data set.
  • Non-Human Identity: Any account or credential used by systems, bots, APIs, scripts, or automated processes.
  • Encryption: The process of converting data into a coded form to prevent unauthorized access.
  • Data Loss Prevention (DLP): Tools or processes that prevent unauthorized sharing, transmission, or exposure of sensitive information.

Policy Requirements

  1. Data Classification:

    • All company data must be classified by the data owner according to sensitivity: Public, Internal, Confidential, or Restricted.
    • Data classification must be clearly documented and reviewed at least annually, or when significant business or regulatory changes occur.
    • Both human and non-human identities must respect classification labels and handling requirements.

  2. Access Controls:

    • Access to sensitive or restricted data is permitted only to authorized identities—human or non-human—based on job duties or system requirements.
    • Permissions must follow the principle of least privilege and be reviewed regularly.

  3. Data Protection:

    • Sensitive and restricted data must be encrypted at rest and in transit using approved cryptographic protocols.
    • Human and non-human identities accessing sensitive data must use secure authentication (e.g., MFA for users, key rotation for APIs).
    • Data must not be stored, copied, or transmitted to unapproved locations or devices.

  4. Data Handling:

    • Data must be handled, stored, shared, and disposed of according to its classification and relevant regulations.
    • Use of DLP solutions is required to prevent unauthorized sharing or exfiltration.

  5. Third-Party Access:

    • Third-party service providers with access to company data must adhere to equivalent data protection and classification standards.
    • Data sharing with third parties must be reviewed and approved by the data owner and IT/Security.

  6. Incident Reporting:

    • Any suspected or actual data breach, loss, or unauthorized disclosure—by human or non-human identities—must be reported immediately to IT/Security.

  7. Audit and Logging:

    • All access to, and handling of, sensitive or restricted data must be logged and regularly reviewed.

Roles and Responsibilities

  • Data Owners: Assign data classification, approve access, and review classification periodically.
  • Data Stewards: Ensure enforcement of protection requirements and report violations.
  • IT/Security Team: Implement technical controls for protection, monitor access, and provide training.
  • Application/Integration Owners: Manage and monitor non-human identity access to data.
  • Users and Non-Human Identities: Handle data only as authorized and report any incidents.

Enforcement / Compliance

  • Failure to comply may result in disciplinary action, removal of access, legal penalties, and/or regulatory sanctions.
  • Supports compliance with HIPAA, GDPR, SOX, PCI DSS, and other relevant data protection regulations.

Exceptions

Any exceptions to this policy must be documented, justified, and approved by the Chief Information Security Officer, and reviewed regularly.

Review and Revision

This policy is reviewed at least annually, or upon changes to applicable law, regulation, or business practices.

Policy Management

Version Control

  • Current version: 1.0
  • Effective date: [Date]
  • Review frequency: Annual or upon significant technology/threat changes

Responsibilities

  • Policy Owner: Chief Information Security Officer
  • Implementation: IT Security Team
  • Compliance Monitoring: Security Operations Center
  • User Support: IT Help Desk

References

  • NIST Special Publication 800-53: Security and Privacy Controls for Information Systems
  • NIST Special Publication 800-60: Guide for Mapping Types of Information and Information Systems to Security Categories
  • ISO/IEC 27001:2013 Annex A.8: Asset Management
  • HIPAA, GDPR, SOX, PCI DSS
  • SANS Data Classification Policy Template

Everyday Identity – Breaking down Identity, one post at a time.
This document is intended as a general best-practices template and should be customized to meet your organization’s specific legal, compliance, and operational needs.