Creating A Data Classification Policy With Examples & Free Template

Pansy

Pansy

Jul 09, 2024

Organizations today handle large amounts of data on a daily basis. It ranges from sensitive customer details to public information. The absence of a structured way to manage this data poses various threats like data breaches, cyber-attacks, data loss, etc. 

This lack of structure can lead to critical data being under-protected and non-sensitive data being over-protected, wasting valuable resources. Furthermore, it could cause non-compliance with frameworks like ISO 27001 and SOC 2 as they require appropriate data management to protect sensitive information.

A data classification policy must, hence be crafted to maintain basic data privacy hygiene and ensure the best practices for protecting information are accomplished. The responsibility for it falls on a company’s data protection team, ISMS team, or IT team.

TL;DR

A data classification policy provides specific instructions on how data must be classified according to its level of sensitivity. The main classifications are public, internal, confidential, private, and restricted. 

The main contents of the data classification policy are purpose, scope, classification groups, impact level, roles and responsibilities, data handling procedures, and appendix. 

The steps to create include assessment of data, defining classification levels, involving key stakeholders, crafting guidelines and conducting annual reviews. 

What is a data classification policy?

A data classification policy is a document that contains guidelines on how information is grouped according to sensitivity and how it should be stored, categorized, and handled. It protects sensitive information and reduces the impact of risks and security breaches. 

Implementing a data classification policy lets you manage data more efficiently by implementing stronger organizational, storage, and handling practices. It clearly defines who can access data, how they handle it, and how it can be processed. 

A data or information classification policy also defines methods for storing sensitive data and specifies measures that need to be in place, such as encryption, backup, security, etc. It also paves the way for a response plan for each category in case of a security incident.

What does a data classification policy include?

A data classification policy includes the criteria for categorizing data based on sensitivity, importance, and definitions of each data classification level. It also acts as a guide on how to handle and access each category of data. 

The key contents of a data classification policy include:

Purpose

Defines the ultimate goal of the policy and what value it provides to the company and its personnel. Explains why the policy is important and how data classification ensures cybersecurity. 

Scope statement

Defines who is subjected to the policy. It determines whether it tends to the whole organization or only selected teams. It also mentions employees, contractors, vendors, and other members to whom the policy applies. 

Data classification groups

This section contains the main groups of data and what kind of data is contained in it. The categories defined may be different for different companies aligning with their industries. These categories help determine the level of security controls needed for different types of data.

The common categories of data classification are confidential, public, or internal use, restricted, and private. 

  • Confidential: Contains highly sensitive data that could cause significant harm if disclosed. 
  • Public: Contains data intended for public release with minimal risk if disclosed. 
  • Internal Use: Contains data meant for internal organizational use, where external disclosure could be harmful.
  • Restricted: Contains the most sensitive data where access is strictly controlled. 
  • Private: Contains high-risk data that can cause harm to individuals or the business under disclosure and should not be used without access. 

Impact level

This section categorizes the data based on the level of impact it can have on the organization based on confidentiality, integrity, and availability of information. It is set according to the potential impact that would be caused if the data were compromised. It can have impact levels of ‘high’, ‘low’, and ‘moderate’ for confidential/restricted, public, and internal/private data, respectively. 

Roles and responsibilities

This section contains the various stakeholders involved in the data management process. It defines the accountable individuals who have respective roles in creating the policy, implementing it, conducting training, complying with industry standards, keeping the policy up-to-date, etc. 

Data handling procedures

This contains guidelines on how data is to be handled according to the different categories. For instance, data categorized as ‘confidential’, has to be stored and transmitted via encryption with access controls. It should also specify how often access logs are reviewed. 

Appendix A: This section of the policy contains the predefined types of data that should be directly categorized as ‘Confidential’ or ‘Protected’. It is a reference for data owners to identify such types of data accurately. 

Data classification policy template and examples

A data classification policy template includes an actionable format that will help you create your own policy. The examples below will help you understand how other businesses draft their policy and what their necessary elements are. 

You can refer to the following template or download a PDF version of a data classification policy format. 

Purpose 

This policy aims to create a framework for classifying data according to its sensitivity, value, and importance to the organization, ensuring that sensitive corporate and customer information is adequately protected.

Scope 

This policy covers all types of data, including physical documents and digital data on any storage medium. It applies to all employees and authorized third-party agents associated with the organization.

Data classification guidelines:

Information asset typeDefinition
Restricted/ConfidentialData with high sensitivity and criticality require the highest level of protection.
PublicData with low sensitivity and criticality can be shared openly.
InternalData with moderate sensitivity and criticality accessible to authorized personnel within the organization.

Impact level determination:

Security ObjectiveDescription of impactImpact Level
ConfidentialityUnauthorized access or disclosure causing financial/legal liabilityHigh
IntegrityUnauthorized access or alteration causing incorrect decision-makingMedium
AvailabilityDisruption of access/Data unavailability causing operational disruptionLow
  • Data owners assess each data piece for sensitivity.
  • If it matches predefined restricted types, assign “High” impact.
  • If not, determine impact using provided guidelines and NIST 800-600 Volume 2.
  • If unsure, collaborate with data custodians for resolution.
  • Based on overall impact level, assign a classification label:
    • High: Restricted
    • Moderate: Confidential
    • Low: Public
  • Record classification label and impact level for each data piece in the official data classification table.

Roles and Responsibilities

  • <Role>: Responsible for overseeing the data classification process and ensuring compliance with this policy.
  • <Role>: Responsible for classifying data according to its sensitivity and assigning appropriate security measures and making category decisions.
  • <Role>: Responsible for implementing security controls based on the classification of data and auditing data access.

Appendix A: Types of Information Classified as “Restricted”

  • Authentication Information: Passwords, cryptographic keys.
  • Payment Card Information (PCI): Credit card number with cardholder name, expiration date, etc.
  • Personally Identifiable Information (PII): Name combined with driver’s license number, financial account number, etc.

Exceptions 

Exceptions must be documented and approved by <Role> and the organization, detailing the nature, rationale, risks, and evidence of approval.

Review 

This policy will be reviewed annually by <Role>.

Next review date: <DATE>

Here are three data classification policy examples that you can refer to:

1. Help Scout –  Data classification policy

2. University of East London – Data classification policy

3. Bentley University – Data classification policy

How do we create a data classification policy?

steps to create a data classification policy

Creating a data classification policy involves defining categories for different types of data to ensure appropriate handling, security, and compliance. This policy helps organizations manage data efficiently, protect sensitive information, and meet regulatory requirements.

The steps for creating a strong data classification policy are:

1. Assess your company’s data 

The first step in creating a data classification policy is to assess what types of data your company is collecting, storing, and processing. This includes both physical and electronic documents and data. 

Create an inventory of your data and analyze it to understand its sensitivity level and the potential risks it entails. You must also consider factors like legal or regulatory requirements, confidentiality, financial impact, and reputational risk.

Learn how to conduct an ISO 27001 risk assessment

2. Define the classification levels

After you have a clear understanding of your company’s data, define the levels of classification based on the types of data in your company. These usually include confidential, private, restricted, internal, and public. 

3. Involve key stakeholders

You need to get approval from members of the board of your organization before creating the data classification policy. Consult with them to have a better understanding of the initial classification and discuss why such a policy is necessary. 

Furthermore, you will also get a clearer idea on the purpose and scope of the policy following the discussion with the stakeholders. Propose a plan of action to craft the policy and review the defined classification levels and what kind of data will fall into each category. 

4. Develop data classification guidelines

The guidelines or instructions for data classification should clearly indicate how to categorize data based on its criticality, the level of impact, risks associated with it, legal requirements, etc. It should also contain protocols to guide the reader to the appendix to be aware of which data is considered confidential by default. 

The instructions should also contain examples about each data category, how they are to be stored and transmitted, and the process for data cleansing. 

Learn more: How to implement a data privacy framework?

5. Conduct annual reviews

The data classification policy must be annually reviewed to ensure that it stays updated with regulatory compliance, business requirements and industry standards. It should also reflect any internal changes in data management within the organisation. 

The Annex A Control 5.12 of ISO 27001:2022 contains a criteria that urges organizations to periodically review information classification. It acknowledges that the level of importance or value a data has may change over time and hence it requires respective updates. 

If you want to know what other requirements have been put forth by ISO 27001:2022 Annex A, you can download the full control list here:

Moving forward with information classification

Data classification forms an important part of a company’s data governance process. According to George Firican, Director of Data Governance, University of British Columbia, classification mitigates risks, enables governance and compliance, improves business efficiency, and makes it easier to analyze information. 

While developing a data or information classification policy keep it mind that it should be customized according to your company’s requirement. There’s no standard that caters to all kinds of industries or companies. It depends on your company’s risks, vulnerabilities, and threat landscape. 

An accurate classification policy will lead the way towards a strong governance structure in your organization with well-defined guidelines, procedures, and accountability frameworks. 

To make things easier, you can use Sprinto’s unified policy library with pre-built templates. You can share the policies organization-wide and ensure all employees have acknowledged them in the platform. 

With Sprinto, you can map policies according to your chosen compliance frameworks. The periodic policy endorsement can be easily shared with auditors during automated evidence collection. 

Stay Ahead with Automated Continuous Compliance

Frequently asked questions

1. What is data classification?

Data classification is the process of organizing data into categories based on its sensitivity, value, and importance to an organization. It helps ensure that sensitive information is appropriately protected, managed, and accessed according to its level of confidentiality and criticality.

2. Why do you need a data classification policy?

A data classification policy ensures that data owners have clear instructions on information is to be grouped. It gives guidelines on which information is considered to be confidential so that essential steps can be taken for its protection and avoiding unauthorized access to it. 

3. What are some examples of protected data?

Examples of protected data include social security number, medical records, identification cards, contact information, addresses, customer information, bank account information, passwords, etc. 

4. What are the four classification types for data?

The four classification types of data are restricted, confidential, public, and internal. 

5. What is ISO 27001 data classification policy?

An ISO 27001 data classification policy, as defined in ISO 27001 Annex A 5.12, involves categorizing information based on the organization’s security needs, focusing on confidentiality, integrity, availability, and the requirements of relevant interested parties.