Note. This page is a copy of the similar CMU page. It needs to be changed to reflect controls for data protection.
The wording of the data definitions has been changed. This needs review by Mike and Joe.

Purpose

The purpose of this Guideline is to establish a framework for classifying data based on its level of sensitivity, value and criticality to the University.

Applies To

At present this guideline applies to members of Information Technology Services at the University.

Definitions

Confidentiality: Preserving authorized restrictions on information access and disclosure, including means for protecting personal privacy and proprietary information

Integrity: Guarding against improper information modification or destruction, and includes ensuring information non-repudiation and authenticity.

Availability: Ensuring timely and reliable access to and use of information.

A Data Steward

A Institutional Data

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:

A.  Restricted Data
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, its stakeholders or its affiliates. In some cases, unauthorized disclosure or loss of this data would require the University to notify the affected individual and provincial authorities. The University would have a contractual, legal, or regulatory obligation to safeguard this data in the most stringent manner; examples are data protected by PHIPA or by PCI-DSS, SIN numbers.
B.  Confidential Data
Data should be classified as Confidential when the unauthorized disclosure, alteration or destruction of that data could adversely affect individuals, the business of the University or its affiliates. Confidential data includes data protected by provincial or federal privacy regulations, as well as for example data protected by confidentiality agreements.
C.  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 the University and its affiliates.  Examples of Public data include 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 of Public data.

 

Classification of data should be performed by an appropriate Data Steward. Data Stewards are senior-level employees of the University who oversee the lifecycle of one or more sets of Institutional Data. See Information Security Roles and Responsibilities for more information on the Data Steward role and associated responsibilities.

Data Collections

Data Stewards may wish to assign a single classification to a collection of data that is common in purpose or function. When classifying a collection of data, the most restrictive classification of any of the individual data elements should be used. For example, if a data collection consists of an employees’s name, work address and SIN number, the data collection should be classified as Restricted even though the employee’s name and address may be considered Public information.

Reclassification

On a periodic basis, it is important to reevaluate the classification of Institutional Data to ensure the assigned classification is still appropriate based on changes to legal and contractual obligations as well as changes in the use of the data or its value to the University. This evaluation should be conducted by the appropriate Data Steward. Conducting an evaluation on an annual basis is encouraged; however, the Data Steward should determine what frequency is most appropriate based on available resources.  If a Data Steward determines that the classification of a certain data set has changed, an analysis of security controls should be performed to determine whether existing controls are consistent with the new classification. If gaps are found in existing security controls, they should be corrected in a timely manner, commensurate with the level of risk presented by the gaps.

Calculating Classification

The goal of information security, as stated in the University’s Information Security Policy, 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.

Unfortunately there is no perfect quantitative system for calculating the classification of a particular data element. In some situations, the appropriate classification may be more 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.  It is an excerpt from Federal Information Processing Standards (“FIPS”) publication 199 published by the National Institute of Standards and Technology, which discusses the categorization of information and information systems.

POTENTIAL IMPACT
Security Objective LOW MODERATE HIGH
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.

 

As the total potential impact to the University increases from Low to High, the classification of data should become more restrictive moving from Public to Restricted. If an appropriate classification is still unclear after considering these points, contact the Information Security Office for assistance.

Additional Information

If you have any questions or comments related to this Guideline, please send email to the Information Security and Enterprise Architecture at ADD IN MAIL ADDRESS.

Please see xxx for applicable University Policies:

DO WE WANT TO KEEP THIS CONCEPT??

Appendix A – Predefined Types of Restricted Information

The Information Security Office and the Office of General Counsel have defined several types of Restricted data based on state and federal regulatory requirements. They’re defined as follows:

1. 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:

  • Passwords
  • Shared secrets
  • Cryptographic private keys
2. Covered Financial Information
See the University’s Gramm-Leach-Bliley Information Security Program.
3. 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:

  • Electronic storage media includes computer hard drives and any removable and/or transportable digital memory medium, such as magnetic tape or disk, optical disk, or digital memory card.
  • 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.
4. 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 Office of Research Integrity and Compliance’s FAQ on Export Control for more information.
5. 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 Services. See Internal Revenue Service Publication 1075 Exhibit 2 for more information.
6. 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
7. 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 Carnegie Mellon’s Policy on Student Privacy Rights for more information on what constitutes an Education Record.

8. 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
9. 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 Carnegie Mellon’s HIPAA Policy. PHI is considered individually identifiable if it contains one or more of the following identifiers:

  • Name
  • 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 indentify an individual

Per Carnegie Mellon’s HIPAA Policy, PHI does not include education records or treatment records covered by the Family Educational Rights and Privacy Act or employment records held by the University in its role as an employer.

10. Controlled Technical Information (“CTI”)
Controlled Technical Information means “technical information with military or space application that is subject to controls on the access, use, reproduction, modification, performance, display, release, disclosure, or dissemination” per DFARS 252.204-7012.