The purpose of this Guideline is to establish a framework for classifying institutional data based on its level of sensitivity, value and criticality to the University as required by the University’s Information Security Policy. Classification of data will aid in determining baseline security controls for the protection of data.
This Policy applies to all faculty, staff and third-party Agents of the University as well as any other University affiliate who is authorized to access Institutional Data. In particular, this Guideline applies to those who are responsible for classifying and protecting Institutional Data.
Confidential Data is a generalized term that typically represents data classified as Restricted, according to the data classification scheme defined in this Guideline. This term is often used interchangeably with sensitive data.
A Data Steward is a senior-level employee of the Seminary who oversees the lifecycle of one or more sets of Institutional Data
Institutional Data is defined as all data owned or licensed by the University.
Non-public Information is defined as any information that is classified as Private or Restricted Information according to the data classification scheme defined in this Guideline.
Sensitive Data is a generalized term that typically represents data classified as Restricted, according to the data classification scheme defined in this Guideline. This term is often used interchangeably with confidential data.
Data classification, in the context of information security, is the classification of data based on its level of sensitivity and the impact to the Seminary 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.
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.
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 Seminary 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 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 a student’s name, address and social security number, the data collection should be classified as Restricted even though the student’s name and address may be considered Public information.
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.
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.
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 the security objective as it pertains to each data set.