Data Classification and Handling Policy (SEC-POL-004)

1. Objective

The objective of this policy is to establish a comprehensive framework for classifying, handling, and protecting [Company Name]’s information assets based on their sensitivity and business value. This policy ensures that appropriate security controls are applied consistently across all information types to meet SOC 2 requirements and protect against unauthorized disclosure.

2. Scope

This policy applies to all [Company Name] workforce members, including employees, contractors, and third parties who create, access, process, store, transmit, or dispose of company information. It encompasses all information in any format (electronic, physical, or verbal) and at any location. This policy covers the entire information lifecycle from creation to secure disposal.

3. Policy

All [Company Name] information shall be classified according to its sensitivity level and handled in accordance with established security controls that protect confidentiality and integrity.

3.1 Information Classification Framework

[Company Name] shall use a three-tier classification system to categorize all information assets:

Public: Information that can be freely shared with the general public without risk to [Company Name] or its stakeholders.

• Examples: Marketing materials, public website content, published research, press releases
• Standard business handling requirements

Internal: Information intended for use within [Company Name] that should not be disclosed to external parties without authorization.

• Examples: Internal policies, business communications, system documentation, employee contact information
• Requires access controls and confidentiality agreements

Confidential: Sensitive information that could cause significant harm to [Company Name], its customers, or business partners if disclosed without authorization.

• Examples: Financial records, customer data, strategic plans, proprietary technology, authentication credentials
• Requires enhanced security controls, encryption, audit logging, and formal access approval

3.2 Information Classification Responsibilities

Information classification shall be assigned by designated information owners and applied consistently throughout the information lifecycle.

• Information owners are responsible for the initial classification of data, approving access requests, and ensuring data is handled according to this policy.

• Classification shall be assigned at the time of creation and documented appropriately.

• When information of different classification levels is combined, the resulting information shall be classified at the highest level of any component.

• Information owners shall review the classification of their information assets annually.

3.3 Handling Requirements by Classification Level

Specific security controls shall be implemented based on information classification levels.

3.3.1 Public Information

• Standard business handling requirements
• May be stored on company systems and transmitted via standard business channels
• Standard backup and archival procedures apply

3.3.2 Internal Information

• Access restricted to authorized [Company Name] workforce members
• Password-protected when stored on portable devices
• Transmitted via secure channels (encrypted email, secure file transfer)
• Stored on company-approved systems with appropriate access controls
• Covered by confidentiality agreements for third-party access

3.3.3 Confidential Information

• Access granted only on a need-to-know basis with formal approval
• Encrypted when stored on laptops, mobile devices, or removable media using [Encryption Standard, e.g., AES-256]
• Transmitted only via encrypted channels (secure email, VPN, HTTPS)
• Stored on secure systems with enhanced access controls and audit logging
• Protected by multi-factor authentication for system access
• All access logged and monitored for unauthorized activity
• Requires appropriate agreements for third-party access
• Must be clearly labeled to indicate classification level
• Subject to data loss prevention (DLP) monitoring and controls

3.4 Data Labeling and Marking

Information classification shall be clearly indicated through appropriate labeling mechanisms.

• Electronic documents shall include classification markings in headers, footers, or metadata when feasible
• Email communications containing Confidential information shall include classification indicators
• Physical documents shall be marked with classification levels when appropriate
• Storage media shall be labeled with the highest classification level of contained information

3.5 Information Storage and Access Controls

Storage requirements shall be implemented based on information classification levels.

• All information systems shall maintain access control lists restricting access based on classification and business need
• Confidential information shall be stored only on systems with appropriate security controls
• Cloud storage of Confidential information requires encryption and compliance with security standards
• Regular access reviews shall be conducted annually for Confidential information
• Automated tools shall be used where feasible to enforce classification-based access controls

3.6 Information Transmission and Sharing

Information transmission methods shall align with classification requirements.

• Public and Internal information may be transmitted via standard business communication channels
• Confidential information shall be encrypted during transmission using approved encryption methods
• File sharing services shall be approved for specific classification levels and configured with appropriate security settings
• Email systems shall include capabilities to prevent unauthorized transmission of sensitive information

3.7 Information Retention and Disposal

Information shall be retained according to business requirements and then securely disposed of when no longer needed.

• Retention schedules shall be established for each information type considering business and legal requirements
• Secure disposal methods shall be used for all Confidential information:
  • Electronic media: Cryptographic erasure or physical destruction
  • Physical documents: Cross-cut shredding or secure destruction
• Disposal activities shall be documented for Confidential information
• Third-party disposal services shall provide certificates of destruction

3.8 Mobile Device and Remote Access

Appropriate controls shall apply to information access via mobile devices and remote locations.

• Mobile devices accessing Confidential information shall be enrolled in mobile device management (MDM) systems
• Remote access to sensitive information shall require VPN connections and multi-factor authentication
• Personal devices used for business purposes shall comply with approved security requirements
• Lost or stolen devices shall be reported immediately and remotely wiped if containing sensitive information

4. Standards Compliance

This policy is designed to comply with and support the following industry standards and regulations.

Policy Section	Standard/Framework	Control Reference
All	SOC 2 Trust Services Criteria	CC6.1 - Logical Access Security
3.5, 3.6	SOC 2 Trust Services Criteria	CC6.7 - Data Transmission
3.7	SOC 2 Trust Services Criteria	CC6.5 - Data Disposal

5. Definitions

Data Loss Prevention (DLP): Technology and processes designed to detect and prevent unauthorized transmission of sensitive information.

Information Owner: The person responsible for the business content and context of information, including classification and access decisions.

Mobile Device Management (MDM): Software that manages, monitors, and secures mobile devices across the organization.

6. Responsibilities

Role	Responsibility
Information Owners	Classify information assets, approve access requests, conduct periodic classification reviews, and ensure appropriate handling.
IT Manager/Security Officer	Develop and maintain classification policies, monitor compliance, and investigate classification violations.
IT Department	Implement technical controls for each classification level and provide secure storage and transmission capabilities.
All Workforce Members	Follow classification and handling requirements, properly label information, and report suspected violations or data loss.
Managers/Supervisors	Ensure their teams understand and comply with classification requirements and approve access requests within their authority.