Data Classification

Document Owner: Chief Information Security Officer
Review Cadence: Quarterly
Last Updated: 2025-11-26
Next Review: 2026-02-26

Executive Summary

Mavaro Systems employs a comprehensive 4-level data classification framework to ensure appropriate protection of all information assets. Each classification level includes specific storage requirements, access controls, encryption standards, retention rules, and audit requirements.

Data Classification Framework

Classification Overview

Mavaro Systems classifies all data into four levels based on sensitivity, business impact, and regulatory requirements. Each classification determines the appropriate security controls, handling procedures, and protection measures.

Classification Hierarchy:

• Public: No special protection required
• Internal: Basic security controls
• Confidential: Enhanced security controls
• Restricted: Maximum security protection

Data Classification Levels

1. Public Data

Definition: Information that can be freely shared with the public without any restriction or potential business impact.

Characteristics:

• No confidentiality requirements
• Public disclosure poses no business risk
• Can be freely distributed and published
• May be used for marketing and public communications

Examples:

• Marketing materials and promotional content
• Press releases and public announcements
• Public product documentation and user guides
• Job postings and career information
• Public website content and social media posts

Storage Requirements:

• Standard file storage with basic backup protection
• No encryption requirements for storage at rest
• Public-facing web servers and content delivery networks acceptable
• Standard access logging and monitoring
• Basic integrity protection measures

Access Controls:

• Open access for all users and systems
• No authentication requirements for public data access
• Standard system access logging
• Basic audit trail maintenance
• Public distribution channels approved

Encryption Requirements:

• No encryption required for data at rest
• Optional TLS encryption for data in transit
• Standard HTTP/HTTPS protocols acceptable
• No special key management requirements
• Optional integrity checking

Retention Rules:

• Retained according to business requirements
• No special retention periods required
• Standard backup and archival procedures
• Public archival acceptable
• Deletion per normal data lifecycle management

Owners: Marketing and Communications teams
Review Cadence: Annual
Evidence Examples:

• Public content approval records
• Website publishing logs and archives
• Marketing material distribution records
• Public communication archives and backups

2. Internal Data

Definition: Information for internal use within Mavaro Systems that may be shared with employees and authorized contractors.

Characteristics:

• Low confidentiality requirements
• Minimal business impact if disclosed to unauthorized parties
• Intended for internal business operations
• May require basic protection measures

Examples:

• Internal policies and procedures
• Employee handbooks and training materials
• Internal newsletters and communications
• System documentation and user guides
• Department operational procedures
• Internal meeting notes and minutes

Storage Requirements:

• Encrypted storage recommended (AES-256 minimum)
• Secure file servers with access controls
• Backup and recovery with encryption
• Standard access logging and monitoring
• Basic integrity protection and versioning

Access Controls:

• All employees and authorized contractors access
• Role-based access control implementation
• Manager approval for external access requests
• Standard authentication and authorization
• Regular access reviews and validation

Encryption Requirements:

• AES-256 encryption for data at rest
• TLS 1.2 minimum for data in transit
• Standard key management procedures
• Regular key rotation (quarterly)
• Basic access control for encryption keys

Retention Rules:

• 7-year retention for business records
• Secure backup and archival procedures
• Encrypted backup storage required
• Controlled access to archived data
• Secure deletion after retention period

Owners: Department Managers and HR
Review Cadence: Quarterly
Evidence Examples:

• Access control matrix and role assignments
• Monthly access review reports
• Encryption key management logs
• Data retention and deletion records
• Internal data distribution controls

3. Confidential Data

Definition: Sensitive business information that could cause significant harm if disclosed to unauthorized parties.

Characteristics:

• High confidentiality requirements
• Significant business impact if disclosed
• Competitive value and sensitivity
• May have regulatory protection requirements

Examples:

• Financial reports and forecasts
• Customer lists and contact information
• Business strategies and plans
• Product roadmaps and development plans
• Employee performance evaluations
• Vendor contracts and pricing
• Research and development data

Storage Requirements:

• Strong encryption required (AES-256 minimum)
• Secure, access-controlled storage systems
• Encrypted backup and recovery procedures
• Enhanced audit logging and monitoring
• Integrity protection and change detection

Access Controls:

• Restricted to employees with business need-to-know
• Multi-factor authentication required
• Manager and supervisor approval required
• Regular access reviews and certifications
• Enhanced audit logging and alerting

Encryption Requirements:

• AES-256 encryption for data at rest (mandatory)
• TLS 1.3 for data in transit (mandatory)
• Hardware security modules for key storage
• Regular key rotation (monthly minimum)
• Advanced key management procedures

Retention Rules:

• 10-year retention for business-critical data
• Encrypted backup and archival storage
• Secure, access-controlled archives
• Regular integrity verification
• Secure destruction after retention period

Owners: Department heads and senior managers
Review Cadence: Monthly
Evidence Examples:

• Data access approval and authorization logs
• Monthly access review and certification records
• Encryption key management audit logs
• Confidential data handling training records
• Data retention and secure deletion evidence
• Business need verification documentation

4. Restricted Data

Definition: Highly sensitive information subject to strict legal and regulatory requirements with severe consequences if compromised.

Characteristics:

• Strictest confidentiality requirements
• Severe legal and financial consequences if compromised
• Subject to specific regulatory compliance
• Requires maximum protection measures

Examples:

• Personal health information (PHI)
• Payment card data (PCI-DSS)
• Social security numbers and tax IDs
• Biometric data and authentication information
• Cryptographic keys and certificates
• Trade secrets and proprietary algorithms
• Classified or restricted business information

Storage Requirements:

• Maximum encryption standards (AES-256 mandatory)
• Dedicated, isolated secure storage systems
• End-to-end encrypted backup and recovery
• Comprehensive audit logging and monitoring
• Advanced integrity protection and tamper detection

Access Controls:

• Strictly limited to authorized personnel only
• Multi-factor authentication mandatory
• Dual authorization for access approval
• Real-time monitoring and alerting
• Comprehensive audit trails and forensics

Encryption Requirements:

• AES-256 encryption for data at rest (mandatory)
• TLS 1.3 for data in transit (mandatory)
• Hardware security modules (mandatory)
• Regular key rotation (weekly minimum)
• Advanced key management with dual control

Retention Rules:

• Regulatory-specific retention requirements
• Encrypted backup and archival with dual control
• Secure, access-controlled archives with monitoring
• Regular integrity and availability verification
• Secure destruction with verification and certification

Owners: Designated data protection officers and security team
Review Cadence: Weekly
Evidence Examples:

• Access authorization and approval logs
• Weekly access certification and validation records
• Hardware security module audit logs and reports
• Restricted data incident response procedures and logs
• Regulatory compliance validation reports
• Secure destruction and certification records
• Dual control verification and acknowledgment

Data Classification Process

Classification Determination

Classification Criteria:

• Business value and sensitivity assessment
• Regulatory and compliance requirements
• Potential impact of unauthorized disclosure
• Legal and contractual obligations
• Industry best practice standards

Classification Decision Process:

1. Data owner assessment and classification proposal
2. Business impact evaluation and risk assessment
3. Regulatory and compliance requirement review
4. Security control requirement determination
5. Final classification approval and documentation

Classification Review:

• Annual classification review and validation
• Quarterly assessment of classification accuracy
• Monthly review of new data classifications
• Regular stakeholder consultation and feedback
• Continuous improvement and optimization

Data Handling Procedures

Classification Marking:

• Clear classification labels on all data
• Automated classification detection when possible
• Manual classification for new or unusual data
• Regular classification validation and correction
• Training on proper classification marking

Handling Requirements:

• Classification-specific handling procedures
• Access control enforcement based on classification
• Encryption and protection measures implementation
• Monitoring and auditing based on classification level
• Incident response procedures for each classification

Change Management:

• Classification changes require approval process
• Impact assessment for classification changes
• Security control updates for classification changes
• Stakeholder notification and training
• Documentation updates and maintenance

Compliance and Governance

Regulatory Requirements

Data Protection Regulations:

• GDPR compliance for EU personal data
• CCPA compliance for California resident data
• HIPAA compliance for health information
• PCI-DSS compliance for payment card data

Industry Standards:

• ISO 27001 information security management
• SOC 2 security and availability controls
• NIST cybersecurity framework compliance
• Industry-specific data protection standards

Governance Structure

Classification Oversight:

• Chief Information Security Officer (CISO)
• Data Protection Officers for regulated data
• Department heads for business data
• Legal counsel for regulatory compliance

Decision Authority:

• Data classification decisions: CISO approval
• Classification changes: Business owner + CISO approval
• Regulatory compliance: Legal counsel consultation
• Security control modifications: Security team approval

Monitoring and Compliance

Compliance Monitoring

Regular Assessments:

• Monthly classification compliance reviews
• Quarterly data handling audit
• Annual comprehensive classification review
• Continuous monitoring and reporting
• Incident-driven assessments

Evidence Collection:

• Access control and authorization logs
• Encryption key management records
• Data retention and deletion evidence
• Training completion and acknowledgment records
• Incident response and resolution documentation

Audit Readiness

Required Documentation:

• Current data classification policies and procedures
• Classification decision records and justifications
• Access control implementation and monitoring evidence
• Encryption and security control deployment records
• Training and awareness program documentation

Audit Support:

• Complete audit trail maintenance
• Evidence preservation and retrieval capabilities
• Stakeholder interview support and coordination
• Corrective action planning and implementation
• Continuous improvement identification and implementation

Training and Awareness

Staff Training Requirements

Classification Training:

• Data classification policy and procedures
• Classification identification and marking
• Handling requirements for each classification level
• Security control implementation and compliance
• Incident reporting and response procedures

Role-Specific Training:

• Data owners: Classification decision-making
• System administrators: Access control implementation
• Security personnel: Monitoring and incident response
• All staff: General classification awareness and compliance

Awareness Programs

Regular Communication:

• Data classification policy updates and changes
• Classification identification and handling reminders
• Security awareness and best practice sharing
• Incident lessons learned and improvement recommendations
• Compliance requirement updates and guidance

Metrics and Performance

Key Performance Indicators

Classification Effectiveness:

• Classification accuracy rate: Target over 95%
• Classification compliance rate: Target 100%
• Access control compliance: Target 100%
• Encryption deployment rate: Target 100% for required data

Operational Metrics:

• Data handling incident rate: Target under 1%
• Classification change processing time: Target under 48 hours
• Training completion rate: Target over 95%
• Audit finding resolution time: Target under 30 days

Regular Reporting

Monthly Reporting:

• Classification compliance status
• Access control effectiveness metrics
• Encryption deployment and management status
• Training completion and awareness metrics

Quarterly Reporting:

• Comprehensive classification review results
• Security control effectiveness assessment
• Compliance audit preparation and validation
• Continuous improvement identification and planning

Continuous Improvement

Improvement Process

Gap Identification:

• Regular classification effectiveness assessment
• Stakeholder feedback collection and analysis
• Regulatory requirement monitoring and updates
• Industry best practice benchmarking

Enhancement Planning:

• Classification process improvement initiatives
• Technology enhancement and automation opportunities
• Training and awareness program enhancement
• Compliance and audit readiness improvement

Implementation and Validation:

• Improvement initiative planning and execution
• Effectiveness measurement and validation
• Stakeholder feedback and satisfaction assessment
• Continuous monitoring and optimization

Conclusion

Mavaro Systems maintains comprehensive data classification framework that ensures appropriate protection of all information assets while enabling effective business operations. Through clear classification criteria, robust security controls, and continuous monitoring, we maintain compliance and security excellence.

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Document Control:

• Version: 2.0
• Effective Date: 2025-11-26
• Supersedes: Version 1.0 (Original Data Classification Policy)
• Next Review: 2026-02-26
• Owner Approval: Pending
• Security Review: Pending