Data Classification Policy
SOC 2 Criteria: C1.1, PI1.1
ISO 27001 Requirements: 7.5.2, 7.5.3
ISO 27001 Annex A: A.5.1.1, A.7.1.2, A.7.2.1, A.8.1.1, A.8.2.1, A.8.2.2, A.16.1.4, A.18.1.3
Keywords: Confidential Data, Internal Data, Public Information, Restricted Data, Classification
Purpose
This policy will assist employees and other third-parties with understanding the Company’s information labeling and handling guidelines. It should be noted that the sensitivity level definitions were created as guidelines and to emphasize common sense steps that you can take to protect sensitive or confidential information (e.g., Company Confidential information should not be left unattended in conference rooms).
Scope
Information covered in this policy includes, but is not limited to, information that is received, stored, processed, or transmitted via any means. This includes electronic, hardcopy, and any other form of information regardless of the media on which it resides.
Roles and Responsibilities
The acting information security officer and team will facilitate and maintain this policy and ensure all employees have reviewed and read the policy.
Policy
Definitions
- Confidential/Restricted Data:
Generalized terms that typically represent data classified as Sensitive or Private, according to the data classification scheme defined in this policy.
- Internal Data:
All data owned or licensed by Userflow.
- Public Information:
Any information that is available within the public domain.
Data Classification Scheme
Data classification, in the context of information security, is the classification of data based on its level of sensitivity and the impact to Userflow should that data be disclosed, altered, or destroyed without authorization. The classification of data helps determine what baseline security controls are appropriate for safeguarding that data. All data should be classified into one of the three following classifications.
Confidential/Restricted Data
Data should be classified as Restricted or Confidential when the unauthorized disclosure, alteration, or destruction of that data could cause a serious or significant level of risk to Userflow or its customers. Examples of Sensitive data include data protected by state or federal privacy regulations (e.g. PHI & PII) and data protected by confidentiality agreements. The highest level of security controls should be applied to Restricted and Confidential Data:
- Disclosure or access to Restricted and Confidential data is limited to specific use by individuals with a legitimate need-to-know. Explicit authorization by the Security Officer is required for access to because of legal, contractual, privacy, or other constraints.
- Must be protected to prevent loss, theft, unauthorized access, and/or unauthorized disclosure.
- Must be destroyed when no longer needed. Destruction must be in accordance with Company policies and procedures.
- Will require specific methodologies, procedures, and reporting requirements for the response and handling of incidents.
Internal Use Data
Data should be classified as Internal Use when the unauthorized disclosure, alteration, or destruction of that data could result in a moderate level of risk to Userflow or its customers. This includes proprietary, ethical, or privacy considerations. Data must be protected from unauthorized access, modification, transmission, storage or other use. This applies even though there may not be a civil statute requiring this protection. Internal Use Data is restricted to personnel who have a legitimate reason to access it. By default, all data that is not explicitly classified as Restricted/Confidential or Public data should be treated as Internal Use data. A reasonable level of security controls should be applied to Internal Use Data.
Public Data
Data should be classified as Public when the unauthorized disclosure, alteration or destruction of that data would result in little or no risk to Userflow and its customers. It is further defined as information with no existing local, national, or international legal restrictions on access or usage. While little or no controls are required to protect the confidentiality of Public data, some level of control is required to prevent unauthorized alteration or destruction of Public Data.
Assessing Classification Level and Labeling
The goal of information security, as stated in the Information Security Policy, is to protect the confidentiality, integrity, and availability of Corporate and Customer Data. Data classification reflects the level of impact to Userflow if confidentiality, integrity, or availability is compromised. If a classification is not inherently obvious, consider each security objective using the following table as a guide. All data are to be assigned one of the following four sensitivity levels:
HANDLING CONTROLS PER DATA CLASSIFICATION
