Information Security: Data Classification
Data classification, in the context of information security, is the classification of data based on its level of sensitivity and the impact to the University 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 institutional data should be classified into one of three sensitivity levels, or classifications:
Data should be classified as Restricted when the unauthorized disclosure, alteration or destruction of that data could cause a significant level of risk to the University or its affiliates. Examples of Restricted data include data protected by state or federal privacy regulations and data protected by confidentiality agreements. The highest level of security controls should be applied to Restricted data.
Restricted information is that which Missouri State has a legal, contractual, or proprietary obligation to protect. For University employees, access to restricted data elements is determined by business process. For non-university employees, access shall be determined by the University’s Custodian of Records in conjunction with the General Counsel’s office.
Examples: Social Security Numbers, personnel records, credit card numbers, medical records, student data that is not considered directory information, BearPass Login with password, information protected by non-disclosure agreements, and confidential research.
Data should be classified as Private when the unauthorized disclosure, alteration or destruction of that data could result in a moderate level of risk to the University or its affiliates. By default, all Institutional data that is not explicitly classified as Restricted or Public data should be treated as Private data. A reasonable level of security controls should be applied to Private data.
For non-university employees, explicit approval by the University’s Records Custodian is needed in order to receive access to Private data elements. Private data elements include those which Missouri State University protects to mitigate institutional risk, or which has been categorized otherwise as Private. Acquisition or distribution of Private data by or between the University agents or employees for a legitimate purpose is allowed, provided that the information is not used in violation of applicable law or in a manner that harms or poses a reasonable threat to the security, confidentiality, or integrity of the information.
Examples: Budget information, procurement, documentation, research that has not been completed or published, vendor documentation, contracts, and BearPass Number.
Data should be classified as Public when the unauthorized disclosure, alteration or destruction of that data would result in little or no risk to the University and its affiliates. Examples of Public data include directory information, press releases, course information and research publications. While little or no controls are required to protect the confidentiality of Public data, some level of control is required to prevent unauthorized modification or destruction.
The goal of information security is to protect the confidentiality, integrity, and availability of Institutional data. Data classification reflects the level of impact to the University if confidentiality, integrity, or availability is compromised.
If you are evaluating data you are responsible for and it does not clearly fall under the laws and regulations listed in the definition, you can apply the Confidentiality, Integrity, and Availability (CIA) criteria. (Most of the legal and regulatory requirements are driven by confidentiality and integrity concerns.)
- Confidentiality: The need to strictly limit access to data to protect the University and individuals from loss.
- Integrity: Data must be accurate, and users must be able to trust its accuracy.
- Availability: Data must be accessible to authorized persons, entities, or devices.
In some situations, the appropriate classification may be obvious, such as when federal laws require the University to protect certain types of data (e.g. personally identifiable information). If the appropriate classification is not inherently obvious, consider each security objective using the following table as a guide.
To determine the level of protections applied to a system or data collection, base your classification on the most confidential data stored, processed, or transmitted by the system. A positive response to the highest category in ANY row is sufficient to place the data into that respective category. Even if the system stores data that could be made available in response to an open records request or information that is public, the entire system must still be protected based on the most confidential data.
|Confidentiality||Preserving authorized restrictions on information access and disclosure, including means for protecting personal privacy and proprietary information.||The unauthorized disclosure of information could be expected to have a limited adverse effect on organizational operations, organizational assets, or individuals.||The unauthorized disclosure of information could be expected to have a serious adverse effect on organizational operations, organizational assets, or individuals.||The unauthorized disclosure of information could be expected to have a severe or catastrophic adverse effect on organizational operations, organizational assets, or individuals.|
|Integrity||Guarding against improper information modification or destruction, and includes ensuring information non-repudiation and authenticity.||The unauthorized modification or destruction of information could be expected to have a limited adverse effect on organizational operations, organizational assets, or individuals.||The unauthorized modification or destruction of information could be expected to have a serious adverse effect on organizational operations, organizational assets, or individuals.||The unauthorized modification or destruction of information could be expected to have a severe or catastrophic adverse effect on organizational operations, organizational assets, or individuals.|
|Availability||Ensuring timely and reliable access to and use of information.||The disruption of access to or use of information or an information system could be expected to have a limited adverse effect on organizational operations, organizational assets, or individuals.||The disruption of access to or use of information or an information system could be expected to have a serious adverse effect on organizational operations, organizational assets, or individuals.||The disruption of access to or use of information or an information system could be expected to have a severe or catastrophic adverse effect on organizational operations, organizational assets, or individuals.|
|Need for Confidentiality||Required (High)||Recommended (Medium)||Optional (Low)|
|Need for Integrity||Required (High)||Recommended (Medium)||Optional (Low)|
|Need for Availability||Required (High)||Recommended (Medium)||Optional (Low)|
If an appropriate classification is still unclear after considering these points, contact the Information Security unit of Information Services for assistance.
For information that is Private or Restricted, printed material should be conspicuously marked, by cover page or page marking, to indicate the classification level.
Appendix A - Predefined Types of Restricted Information
There are several types of Restricted data based on state and federal regulatory requirements:
- Authentication Verifier
An Authentication Verifier is a piece of information that is held in confidence by an individual and used to prove that the person is who they say they are. In some instances, an Authentication Verifier may be shared amongst a small group of individuals. An Authentication Verifier may also be used to prove the identity of a system or service. Examples include, but are not limited to:
- Shared secrets
- Cryptographic private keys
- Covered Financial Information
- Electronic Protected Health Information ("ePHI")
ePHI is defined as any Protected Health Information ("PHI") that is stored in or transmitted by electronic media. For the purpose of this definition, electronic media includes:
- Computer hard drives and any removable and/or transportable digital memory medium, such as magnetic tape or disk, optical disk, digital memory card, or USB key.
- Transmission media used to exchange information already in electronic storage media. Transmission media includes, for example, the Internet, an extranet (using Internet technology to link a business with information accessible only to collaborating parties), leased lines, dial-up lines, private networks and the physical movement of removable and/or transportable electronic storage media. Certain transmissions, including of paper, via facsimile, and of voice, via telephone, are not considered to be transmissions via electronic media because the information being exchanged did not exists in electronic form before the transmission.
- Export Controlled Materials
Export Controlled Materials is defined as any information or materials that are subject to United States export control regulations including, but not limited to, the Export Administration Regulations (“EAR”) published by the U.S. Department of Commerce and the International Traffic in Arms Regulations (“ITAR”) published by the U.S. Department of State. See the Export Controls Policy, Op4.01-3 Export Controls Policy, for more information.
- Federal Tax Information ("FTI")
FTI is defined as any return, return information or taxpayer return information that is entrusted to the University by the Internal Revenue Service. See Internal Revenue Service Publication 1075 Exhibit 2 for more information.
- Payment Card Information
Payment card information is defined as a credit card number (also referred to as a primary account number or PAN) in combination with one or more of the following data elements:
- Cardholder name
- Service code
- Expiration date
- CVC2, CVV2 or CID value
- PIN or PIN block
- Contents of a credit card’s magnetic stripe
- Personally Identifiable Education Records
Personally Identifiable Education Records are defined as any education records that contain one or more of the following personal identifiers:
- Name of the student
- Name of the student’s parent(s) or other family member(s)
- Social security number
- Student number
- A list of personal characteristics that would make the student’s identity easily traceable
- Any other information or identifier that would make the student’s identity easily traceable
See Missouri State University’s policy on Student Rights, Op5.11-1 Notification of Student Rights, information on what constitutes an education record.
- Personally Identifiable Information
For the purpose of meeting security breach notification requirements, PII is defined as a person’s first name or first initial and last name in combination with one or more of the following data elements:
- Social security number
- State-issued driver’s license number
- State-issued identification card number
- Financial account number in combination with a security code, access code or password that would permit access to the account
- Medical and/or health insurance information
- Protected Health Information ("PHI")
PHI is defined as "individually identifiable health information" transmitted by electronic media, maintained in electronic media or transmitted or maintained in any other form or medium by a Covered Component, as defined in Missouri State University’s HIPAA Policy, Op7.07-6 HIPAA and Security. PHI is considered individually identifiable if it contains one or more of the following identifiers:
- Address (all geographic subdivisions smaller than state including street address, city, county, precinct or zip code)
- All elements of dates (except year) related to an individual including birth date, admissions date, discharge date, date of death and exact age if over 89)
- Telephone numbers
- Fax numbers
- Electronic mail addresses
- Social security numbers
- Medical record numbers
- Health plan beneficiary numbers
- Account numbers
- Certificate/license numbers
- Vehicle identifiers and serial numbers, including license plate number
- Device identifiers and serial numbers
- Universal Resource Locators (URLs)
- Internet protocol (IP) addresses
- Biometric identifiers, including finger and voice prints
- Full face photographic images and any comparable images
- Any other unique identifying number, characteristic or code that could identify an individual