Data Classification and Handling Policy (SEC-POL-004)
1. Objective
This policy establishes a comprehensive systematic approach for classifying, handling, and protecting data assets based on their sensitivity, value, and regulatory requirements. The policy ensures that appropriate security controls are applied throughout the entire data lifecycle in the video streaming platform environment, providing robust protection for user data, business information, and platform operations while maintaining compliance with applicable regulations.
2. Scope
This policy applies comprehensively to all data created, processed, transmitted, or stored by [Company Name] across all operational environments. The scope encompasses user-generated content, user personal data, business information, and system data in all formats. All employees, contractors, and third parties who handle Company data in any format, whether digital or physical, must comply with these requirements.
3. Policy
3.1 Data Classification Framework
All data must be classified into one of the following categories based on sensitivity and potential impact of unauthorized disclosure:
Public: Information that can be freely shared without risk to [Company Name] or users
- Marketing materials and press releases
- Published platform policies and terms of service
- General product information and features
Internal: Information intended for internal use that could cause minor harm if disclosed
- Internal communications and meeting notes
- Non-sensitive operational procedures
- Aggregated, anonymized usage statistics
Confidential: Sensitive information that could cause significant harm if disclosed
- Individual user viewing histories and preferences
- Non-aggregated user behavioral data
- Business strategies and financial information
- Vendor contracts and partnership agreements
Restricted: Highly sensitive information that could cause severe harm if disclosed
- Mass user personally identifiable information (PII) databases
- Core recommendation algorithm source code
- Cryptographic keys and security credentials
- Government request data and law enforcement communications
User-Generated Content (UGC): Content created by platform users requiring special handling
- User-uploaded videos, images, and audio
- User comments, reviews, and social interactions
- User profile information and metadata
- Content moderation decisions and appeals
3.2 Data Handling Requirements
Data handling requirements vary by classification level:
Public Data:
- No special handling requirements
- Can be shared through any approved communication channel
- Standard backup and retention applies
Internal Data:
- Accessible only to employees and authorized contractors
- Transmitted using encrypted channels
- Stored on approved Company systems
- Standard access logging required
Confidential Data:
- Access restricted to authorized personnel with business need
- Encrypted in transit and at rest
- Enhanced access logging and monitoring
- Requires data processing agreements for third-party access
Restricted Data:
- Access limited to specifically authorized individuals
- Multi-factor authentication required for access
- Encrypted using approved strong encryption algorithms
- Comprehensive access audit logging and real-time monitoring
- Requires executive approval for third-party sharing
User-Generated Content (UGC):
- Subject to content moderation and safety scanning
- Stored with appropriate geographic data residency requirements
- Accessible to users per their privacy settings
- Retention based on user preferences and legal requirements
- Special handling for content from users under 18 years of age
3.3 Data Labeling and Marking
- All data must be labeled with appropriate classification markings
- Electronic files must include metadata indicating classification level
- Database records must include classification fields
- Data labels must be maintained throughout the data lifecycle
- Automated classification tools should be used where possible
3.4 Data Sharing and Transfer
Data sharing must comply with classification requirements:
- Written approval required for sharing Confidential or Restricted data
- Data Processing Agreements required for external data sharing
- Cross-border transfers must comply with applicable data protection laws
- Secure transfer mechanisms required for sensitive data
- Regular audits of data sharing arrangements
3.5 Data Retention and Disposal
- Data retention periods must align with business needs and legal requirements
- UGC retention based on user account status and content policies
- User PII retention limited to minimum necessary periods
- Secure disposal procedures required for all data classifications
- Certificate of destruction required for Restricted data disposal
4. Standards Compliance
| Policy Section | Standard/Framework | Control Reference |
|---|---|---|
| 3.1, 3.2 | ISO/IEC 27001:2022 | A.8.2.1 |
| 3.1 | PCI DSS v4.0 | Req. 3.3.1 |
| 3.2 | SOC 2 Type II | CC6.1 |
| 3.2 | GDPR | Art. 32 |
| 3.2 | PCI DSS v4.0 | Req. 3.1, 3.4 |
| 3.4 | CCPA | § 1798.100 |
| 3.4 | EU Digital Services Act | Art. 26 |
| 3.4 | PCI DSS v4.0 | Req. 4.1, 4.2 |
| 3.5 | GDPR | Art. 17 |
| 3.5 | COPPA | § 312.10 |
| 3.5 | PCI DSS v4.0 | Req. 3.2.1 |
5. Definitions
Data Classification: The process of organizing data into categories based on sensitivity, value, and regulatory requirements.
User-Generated Content (UGC): Any content created and uploaded by platform users, including videos, comments, and profile information.
Personally Identifiable Information (PII): Information that can be used to identify, contact, or locate a specific individual.
Data Processing Agreement (DPA): A contract that defines the data protection responsibilities when personal data is processed by third parties.
Data Residency: Requirements for data to be stored and processed within specific geographic boundaries.
Cross-Border Transfer: Movement of data across national or regional boundaries, subject to data protection regulations.
6. Responsibilities
| Role | Responsibility |
|---|---|
| Data Owners | Determine appropriate classification levels, approve access requests, and ensure compliance with handling requirements. |
| Data Custodians | Implement technical and administrative controls to protect data according to classification requirements. |
| All Employees | Properly classify data they create or handle, follow handling procedures, and report classification concerns. |
| [Security Department/Team Name] | Monitor data handling compliance, investigate violations, and maintain classification tools and procedures. |
| [Privacy Department/Team Name] | Ensure data classification aligns with privacy requirements and support data subject rights fulfillment. |
| [Legal Department/Team Name] | Provide guidance on regulatory requirements affecting data classification and handling procedures. |