Free Data Management Policy Builder

1. Purpose

This policy establishes requirements for classifying, handling, storing, and disposing of data throughout its lifecycle. The goal is to ensure that data is protected according to its sensitivity level, regulatory requirements are met, and data is managed consistently across the organization in accordance with SOC 2 and industry best practices.

2. Scope

Applies to all data created, received, processed, stored, or transmitted by the organization, regardless of format (electronic or physical). Includes structured data (databases), unstructured data (documents, emails), and data on all systems, applications, cloud services, and physical media. Covers all employees, contractors, vendors, and third parties who handle organizational data.

3. Roles

• Chief Security Officer (CSO) – owns this policy, approves data classification criteria, oversees data management program
• Data Protection Officer (DPO) – manages data privacy compliance, coordinates data subject requests, maintains data processing records
• Data Owners – business leaders responsible for specific data sets, approve access, define retention requirements
• Data Stewards – implement data handling procedures, maintain data quality, ensure compliance with data classification
• Data Custodians – IT personnel who manage technical security controls, backups, and infrastructure for data storage
• All Employees – handle data according to its classification, report data incidents, complete data handling training

4. Core Principles

• Classify all data – every data set must have an assigned classification level
• Protect based on classification – apply security controls appropriate to data sensitivity
• Minimize data collection – collect only data necessary for business purposes
• Retain only as needed – delete data when no longer required for business or legal purposes
• Dispose securely – ensure data is irrecoverably destroyed when disposed

5. Data Classification

5.1 Classification Levels

Restricted Data

Definition: Highly sensitive data that, if disclosed, could cause severe harm to the organization, customers, or individuals.

Examples:

• Customer personally identifiable information (PII): Social Security numbers, driver's license numbers, passport numbers
• Payment card information (PCI): Credit/debit card numbers, CVV codes, card holder data
• Protected health information (PHI): Medical records, health insurance information
• Authentication credentials: Passwords, API keys, private keys, certificates
• Financial data: Bank account numbers, financial statements, tax records
• Legal documents: Contracts under NDA, attorney-client privileged communications

Handling Requirements:

• Encryption at rest (AES-256) and in transit (TLS 1.2+) - MANDATORY
• Access restricted to authorized personnel only (least privilege, need-to-know basis)
• Multi-factor authentication required for access
• Audit logging of all access and modifications
• Annual access reviews
• Cannot be transmitted via unencrypted email
• Cannot be stored on personal devices or removable media
• Secure disposal required (cryptographic erasure or physical destruction)

Confidential Data

Definition: Sensitive business information that, if disclosed, could harm the organization's competitive position or operations.

Examples:

• Business plans, strategies, and forecasts
• Customer lists and non-public customer information
• Proprietary code, algorithms, and technical designs
• Internal financial data and budgets
• Employee data: Salaries, performance reviews, HR records
• Security policies and incident reports
• Merger and acquisition information
• Vendor contracts and pricing information

Handling Requirements:

• Encryption in transit (TLS 1.2+) - MANDATORY
• Encryption at rest - RECOMMENDED
• Access restricted to employees with legitimate business need
• Can be transmitted via encrypted email or secure file sharing
• Should not be stored on personal devices without encryption
• Secure disposal required (overwrite or shred)
• Non-disclosure agreements required for external parties

Internal Data

Definition: Internal business information not intended for public disclosure but not highly sensitive.

Examples:

• Internal memos and communications
• Project documentation and plans
• Employee directories and org charts
• Internal training materials
• Meeting notes and presentations
• Internal wikis and knowledge bases

Handling Requirements:

• Encryption in transit - RECOMMENDED
• Access restricted to employees (company-wide or team-based)
• Can be transmitted via email within the organization
• Should not be shared with external parties without approval
• Standard disposal methods acceptable (delete files, recycle paper)

Public Data

Definition: Information intended for public disclosure or already publicly available.

Examples:

• Marketing materials and press releases
• Public website content
• Published blog posts and articles
• Product documentation and user guides
• Job postings

Handling Requirements:

• No special handling requirements
• Can be freely shared and distributed
• Standard disposal methods acceptable

5.2 Data Classification Process

• Initial Classification: Data Owner classifies data upon creation or acquisition
• Classification Criteria: Based on sensitivity, regulatory requirements, and business impact
• Labeling: Apply classification labels to documents, files, databases, and systems
• Documentation: Record classification in data inventory
• Review: Review classification annually or when data usage changes
• Reclassification: Data Owner can reclassify data if sensitivity changes (upgrade or downgrade)

6. Data Inventory

6.1 Data Inventory Requirements

The organization maintains a comprehensive data inventory including:

• Data Category: Type of data (customer PII, financial data, employee data, etc.)
• Data Classification: Restricted, Confidential, Internal, or Public
• Data Owner: Business owner responsible for the data
• Storage Location: Where data is stored (AWS S3, databases, file shares, etc.)
• Data Format: Structured (database) or unstructured (files, documents)
• Collection Method: How data is collected (user input, API, third party, etc.)
• Processing Purpose: Business purpose for collecting and processing data
• Retention Period: How long data is retained
• Disposal Method: How data is disposed when no longer needed
• Third-Party Sharing: External parties who have access to the data
• Regulatory Requirements: GDPR, CCPA, HIPAA, PCI-DSS, etc.

6.2 Data Discovery

• Conduct data discovery assessments annually to identify all data across the organization
• Use automated tools to scan systems for sensitive data (data loss prevention tools, cloud security posture management)
• Interview business units to understand data types and usage
• Map data flows to understand how data moves through systems
• Update data inventory based on discovery findings

7. Data Lifecycle Management

7.1 Data Collection and Creation

• Data Minimization: Collect only data necessary for defined business purposes
• Consent: Obtain appropriate consent for collecting personal data (where required by law)
• Privacy Notice: Provide clear privacy notice about data collection and use
• Classification at Creation: Classify data upon creation or acquisition
• Secure Collection: Use encrypted channels (HTTPS, TLS) for collecting sensitive data

7.2 Data Storage and Processing

• Approved Systems: Store data only in approved, secure systems (no personal cloud storage for business data)
• Encryption: Encrypt data at rest and in transit based on classification level
• Access Controls: Implement role-based access controls and least privilege
• Data Quality: Maintain data accuracy and completeness
• Backup: Back up critical data according to Backup Management Policy
• Data Residency: Store data in approved geographic locations per regulatory requirements

7.3 Data Sharing and Transmission

• Internal Sharing: Share data internally only with employees who have business need
• External Sharing: Require Data Owner approval for sharing with third parties
• Third-Party Agreements: Execute Data Processing Agreements (DPA) with vendors processing data on our behalf
• Secure Transmission: Use encrypted channels for transmitting sensitive data (HTTPS, SFTP, encrypted email)
• Data Transfer Logging: Log all transfers of Restricted data to external parties

7.4 Data Retention

Retention Schedule by Data Type:

• Customer Account Data: 7 years after account closure (or per regulatory requirements)
• Financial Records: 7 years (IRS requirement)
• Audit Logs: Minimum 1 year (SOC 2), up to 7 years for compliance logs
• Employee Records: 7 years after termination (or per state/federal law)
• Contracts: 7 years after contract expiration
• Marketing Data: Until opt-out or 3 years of inactivity
• Application Logs: 90 days (unless security-related)
• Email: Per organization retention policy (typically 1-7 years)

Retention Policy Requirements:

• Data Owner defines retention period based on business need and legal requirements
• Automated deletion processes configured for data with defined retention periods
• Legal hold procedures for data subject to litigation or investigation
• Annual review of retention schedules

7.5 Data Disposal

Electronic Data Disposal

Restricted Data:

• Cryptographic erasure (delete encryption keys) - PREFERRED
• Multi-pass overwrite (DoD 5220.22-M standard: 7-pass overwrite)
• Physical destruction of storage media containing data (shredding, degaussing, crushing)
• Certificate of destruction obtained from third-party disposal vendor

Confidential and Internal Data:

• Standard deletion or single-pass overwrite
• Secure deletion tools for sensitive files

Physical Media Disposal

• Paper Documents (Restricted/Confidential): Cross-cut shredding (minimum 3/32" x 5/8" particles)
• Hard Drives: Degaussing followed by physical destruction, or crushing/shredding
• Solid State Drives (SSD): Cryptographic erasure or physical destruction (degaussing ineffective)
• USB Drives and Removable Media: Physical destruction (crushing, shredding)
• Mobile Devices: Factory reset + encryption key deletion, or physical destruction

Disposal Process

• Data disposal requests logged and approved by Data Owner
• IT executes disposal using approved methods
• Certificate of destruction obtained and retained for audit
• Disposal activities logged with date, method, personnel, and data description
• Media pending disposal stored in secure facility

8. Data Subject Rights (Privacy)

For personal data subject to GDPR, CCPA, or similar regulations, the organization supports the following data subject rights:

8.1 Right of Access

• Individuals can request access to their personal data
• Provide copy of data in human-readable format within 30 days
• Verify identity before disclosing data

8.2 Right to Rectification

• Individuals can request correction of inaccurate data
• Update data within 30 days of verified request
• Notify third parties if data was shared

8.3 Right to Erasure (Right to be Forgotten)

• Individuals can request deletion of personal data
• Delete data within 30 days unless legal retention requirement applies
• Document reasons if deletion request is denied

8.4 Right to Data Portability

• Provide data in machine-readable format (JSON, CSV)
• Enable data transfer to another service provider if requested

8.5 Right to Object

• Individuals can object to processing of their data
• Cease processing unless compelling legitimate grounds exist
• Opt-out of marketing communications honored immediately

8.6 Data Subject Request Process

• Submit requests via email to privacy@yourcompany.com
• Verify identity using authentication or government-issued ID
• Respond within 30 days (or 45 days with extension notice)
• Log all data subject requests in tracking system
• Coordinate with DPO for complex requests

9. Data Breach Notification

• Notify affected individuals if personal data breach occurs (reference: Incident Response Plan)
• GDPR: Notify supervisory authority within 72 hours of discovery
• CCPA: Notify California residents without unreasonable delay
• State Laws: Follow state-specific breach notification requirements
• Breach notification includes: date of breach, types of data affected, actions taken, contact information

10. Third-Party Data Sharing

• Maintain inventory of third parties who process data on behalf of organization
• Execute Data Processing Agreements (DPA) with all data processors
• Conduct vendor security assessments before sharing data
• Verify third-party compliance with security and privacy standards
• Monitor third-party compliance through annual assessments or audits
• Include data return/deletion requirements in vendor agreements

11. Data Quality and Accuracy

• Data Stewards responsible for maintaining data quality
• Implement data validation at point of entry
• Conduct periodic data quality reviews
• Correct inaccurate data promptly upon discovery
• Archive or delete outdated data per retention schedule

12. Training and Awareness

• All employees complete data handling training during onboarding
• Annual security awareness training includes data classification and handling procedures
• Data Owners and Data Stewards receive specialized training on data governance
• Privacy training for personnel handling personal data (GDPR, CCPA compliance)
• Role-specific training for IT personnel on data disposal procedures

13. Compliance and Monitoring

• Security Team conducts annual data classification compliance audits
• Data inventory reviewed and updated quarterly
• Data retention schedules reviewed annually
• Data disposal logs audited quarterly
• Access to Restricted data reviewed quarterly
• Data subject request metrics reported monthly

14. Exceptions

Exceptions to this policy require Chief Security Officer approval with documented business justification, risk assessment, compensating controls, and defined timeframe. Data Owner must approve any exceptions affecting their data.

15. Enforcement

Violations of this policy, including mishandling classified data, unauthorized data sharing, or improper disposal, may result in disciplinary action up to and including termination. Intentional misuse of data is grounds for immediate termination and potential legal action.

16. References

• SOC 2 – Confidentiality Criteria
• GDPR (General Data Protection Regulation)
• CCPA (California Consumer Privacy Act)
• NIST SP 800-88 – Guidelines for Media Sanitization
• [Your Company] Information Security Policy
• [Your Company] Privacy Policy
• [Your Company] Cryptographic Management Policy
• [Your Company] Access Management Policy

17. Revision History

Date	Version	Author	Description
[Date]	1.0	Chief Security Officer	Initial release