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Data Classification

Data classification is the process of analyzing and organizing both structured and unstructured data by categorizing it based on content, confidentiality, information type, and other relevant characteristics. 

This process is crucial for understanding what data is collected, stored, and processed, enabling you to prioritize and protect the most critical information. Additionally, accurate data classification is essential for meeting compliance requirements, as it enhances preparedness for external audits and ensures a more efficient response to auditor inquiries. 

Follow these simple steps to classify and safeguard your information and data: 

Step 1: Data classification involves multiple steps and a structured approach to ensure compliance with relevant standards. Maintaining a consistent and organized methodology is essential. Therefore, start by familiarizing yourself with the data classification process and the requirements outlined in the Security Policy Framework, which can be accessed in the Compleye Online Templates Section. 

Step 2: Once the concept of Data Classification and its alignment with business needs is understood, the next step is to identify the sources of data. Examples of data sources include HR data, source code, intellectual property (IP), customer data, compliance documentation, business data, and financial data. 

Step 3: Data should be classified based on its sensitivity and criticality to the organization. Common categories may include: 

  • Public 
  • Internal 
  • Confidential 
  • Restricted or Highly Confidential 

 

These categories help define the level of protection and controls required for each type of data. However, you can establish your own data classification categories and expand them as needed to align with your business requirements. 

Step 4: Once the data sources are identified, it is essential to evaluate the Security Impact of each data source based on its sensitivity and potential consequences if compromised, as per below example. This involves assessing the impact of data breaches, loss, or unauthorized access, and aligning each data source with the appropriate security measures and controls, as outlined below:           

Secure Objective 
Low 
Moderate 
High 
Confidentiality 

 
 
Preserving authorized restrictions on information access and disclosure, including means for protecting personal privacy and proprietary information. 
The unauthorized disclosure of information could be expected to have a limited adverse effect on organizational operations, organizational assets, or individuals. 
The unauthorized disclosure of information could be expected to have a serious adverse effect on organizational operations, organizational assets, or individuals. 
The unauthorized disclosure of information could be expected to have a severe or catastrophic adverse effect on organizational operations, organizational assets, or individuals. 
Integrity 
 
 
 
Guarding against improper information modification or destruction includes ensuring information non-repudiation and authenticity. 
The unauthorized modification or destruction of information could be expected to have a limited adverse effect on organizational operations, organizational assets, or individuals. 
The unauthorized modification or destruction of information could be expected to have a serious adverse effect on organizational operations, organizational assets, or individuals. 
The unauthorized modification or destruction of information could be expected to have a severe or catastrophic adverse effect on organizational operations, organizational assets, or individuals. 
Availability 
 
 
 
Ensuring timely and reliable access to and use of information. 
The disruption of access to or use of information or an information system could be expected to have a limited adverse effect on organizational operations, organizational assets, or individuals. 
The disruption of access to or use of information or an information system could be expected to have a serious adverse effect on organizational operations, organizational assets, or individuals. 
The disruption of access to or use of information or an information system could be expected to have a severe or catastrophic adverse effect on organizational operations, organizational assets, or individuals. 

Step 5: Establish clear and specific criteria to handle the classification of data. This includes understanding the nature of the data, its potential impact if exposed, and its importance to the organization’s operations. For example, personal data, financial records, and intellectual property require more stringent controls compared to internal communications or publicly available documents. 

To provide a real-life example of data classification, let’s explore how HR data would be classified, along with the controls and handling requirements: 

  • Classification: Restricted 
  • Security Impact: High 
  • Reason: Contains personal and confidential employee information, including salaries, health details, and performance reviews. Breaches could result in reputational damage, legal penalties, and loss of employee trust. 
  • Controls and Handling Requirements:
    Encrypt data at rest and in transit. 
    Restrict access to authorized HR personnel only. 
    Implement multi-factor authentication (MFA) for system access. 
    Conduct regular access audits and maintain logs.
    Ensure compliance with GDPR and local labor laws.
    Maintain secure backup and retention policies.
    Train HR staff on data protection and security policies 

Step 6: Engage data owners, security teams, and other relevant stakeholders in defining and classifying data. This ensures that the classification process aligns with organizational goals and compliance requirements. 

Step 7: Once data is classified, it is important to document the classification. You must determine whether your information and data should be labeled. Adopting a labeling strategy is a choice that needs to be made. If you decide not to implement labeling, you must reflect this in your Statement of Applicability (SoA). In the SoA Templace, which can be accessed in Compleye Online Templates Section, as well as embedded in ISRA, we provide examples of how to define the justification for not labeling. It is crucial that you fully understand this reasoning, as it will be subject to review by external auditors. 

Step 8: Data classification should be reviewed periodically to ensure its accuracy and relevance. Changes in business processes, regulations, or the nature of the data may require reclassification. Implementing an Operational Planning and Control (OPC) can help review and assess the correctness of the data classification overview on a scheduled basis. 

Step 9: Based on the classification, implement appropriate access control measures. More sensitive data should only be accessible to authorized personnel, while less sensitive data may have fewer restrictions. This could include encrypting sensitive data and applying role-based access controls. 

Step 10: Ensure that your data classification process complies with relevant data protection laws (e.g., GDPR, HIPAA). Incorporate these legal requirements into your classification and data protection policies. 

Step 11: It is essential to ensure that employees understand the importance of data classification and their responsibilities in handling classified data. Provide training on how to classify data and how to manage it according to its classification level. 

Field

Example Content

Data source

HR Data *

Collected from / Transferred

information via Team Members (E-mail)

GDPR role

controller

Data Classification

Restricted 

Labelling

NA

Handling of assets

Only CEO has access to all of the data. 

Implemented control  measures

Restricted on Access in MS365

Regulatory, Quality Requirement

GDPR

Data Storage

MS365 in separate folder HR Team Members

System Access Overview

Compleye Online – MS365

Security Impact

Moderate

Confidentiality

High

Integrity

High

Availability

Low

Security policies/procedures

HR-Office procedure and Access Management Procedure

Add new field

[you can add extra fields – if needed]

Data Ownership

Data is owned by Team Members. 

*Examples of Data sources:  HR Data, Source Code, Customer Data, Compliance Documentation, Business Data, Financial Data. 

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