ISO Policies, Standards, and Guidelines
Data Classification Standard
Last reviewed: 06/24/2013
This standard serves as a supplement to the Information Resources Use and Security Policy, which was drafted in response to Texas Administrative Code 202 and UT System UTS-165. Adherence to the standard will facilitate applying the appropriate security controls to university data.
The objective of this standard is to assist data stewards, IT owners and custodians in the assessment of information systems to determine what level of security is required to protect data on the systems for which they are responsible. The standard divides data into three categories:
This standard exists in addition to all other university policies and federal and state regulations governing the protection of the university's data. Compliance with this classification standard will not ensure that data will be properly secured. Instead, this standard should be integrated into a comprehensive information security plan.
All university data stored, processed, or transmitted on university resources or other resources where university business occurs must be classified into one of the three categories. Based on the data classification you determine for your system, you are required to implement appropriate technical security measures to protect the data consistent with the university Minimum Security Standards. Category-I data has more stringent requirements than Categories II and III. All systems require some protective measures.
All faculty, staff, student employees, contractors, and vendors working with University of Texas at Austin data.
4. Data Classification Standard
To classify your data, you must start by understanding what the classifications are. There are specific laws and regulations that govern some kinds of data. Additionally, there are situations where you must consider whether the confidentiality, integrity, or availability of the data is a factor. Finally, consider that you may be storing information on more than one system, such as moving data between computers by CD or flash drive, for example. If you rate only your primary computer as Category-I, but not your secondary computer or the transfer media, the secondary computer could put data at risk because it won't be well protected.
4.1. Category-I Data
University data protected specifically by federal or state law or University of Texas rules and regulations (e.g., HIPAA; FERPA; U.S. Export Controlled information; Sarbanes-Oxley, Gramm-Leach-Bliley; the Texas Identity Theft Enforcement and Protection Act; University of Texas System Policies; specific donor and employee data). University data that are not otherwise protected by a known civil statute or regulation, but which must be protected due to contractual agreements requiring confidentiality, integrity, or availability considerations (e.g., Non Disclosure Agreements, Memoranda of Understanding, Service Level Agreements, Granting or Funding Agency Agreements, etc.) See the extended list of Category-I data classification examples for specifics."
Protect your Category-I data by applying the appropriate Minimum Security Standards.
4.2. Category-II Data
University data not otherwise identified as Category-I data, but which are releasable in accordance with the Texas Public Information Act (e.g., contents of specific e-mail, date of birth, salary, etc.) Such data must be appropriately protected to ensure a controlled and lawful release.
Protect your Category-II data by applying the appropriate Minimum Security Standards.
4.3. Category-III Data
University data not otherwise identified as Category-I or Category-II data (e.g., publicly available). Such data have no requirement for confidentiality, integrity, or availability.
Protect your Category-III data by applying the appropriate Minimum Security Standards.
5. Using C-I-A to Help Classify Data for Which You Are Responsible
If you are evaluating data you are responsible for and it doesn't 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.)
To determine the level of protections applied to a system, 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.
Once you classify data you are responsible for, review the university Minimum Security Standards. These standards describe the appropriate steps for protecting data based on the data classification.
5.1. Data Classification Examples
This section illustrates how the ISO classifies some familiar data using the CIA (Confidentiality, Integrity, Availability) criteria.
5.1.1. Category-I Data: Web Central
Web Central is considered Category-I data because it is governed by a service-level agreement that dictates a high level of uptime.
5.1.2. Category-I Data: Digital Research Data with a Funding Agency Agreement
Digital research data is required to be confidential (high) due to various factors, including human subject data, requirements of granting or funding agency agreements, etc. Integrity of the research is required (high) because the data must be accurate and free from errors to be credible. Availability is recommended (medium), because The University of Texas at Austin is not necessarily in any danger or in violation of any law if the data is unavailable for a period of time.
5.1.3. Category-II Data: Large Numbers of E-mail Addresses
University e-mail addresses are considered Category-II data. By law they are public information and are published in the university directory (unless restricted by individuals). However, the directory is not intended to be used to harvest e-mail addresses. People must submit open records requests to get e-mail addresses.
5.1.4. Category-III Data: Professor's Blog
A blog is by its very nature
designed to be shared with the world. The confidentiality requirement is
therefore optional (low). If the contents of the blog are changed, there would
be little to no impact on the ability of the department or the university to
carry out their missions. The need for integrity is therefore optional (low).
The need for availability is also optional (low) because, should the blog be
taken offline for a period of time, the only primary people affected would be
the readers of the blog. The department and university should be able to carry
on business as usual, while the blog was restored or recreated.
6. Non-Compliance and Exceptions
Non-compliance with these standards may result in revocation of system or network access, notification of supervisors, and reporting to the Office of Internal Audit.
University of Texas at Austin employees are required to comply with both institutional rules and regulations and applicable UT System rules and regulations. In addition to university and System rules and regulations, University of Texas at Austin employees are required to comply with state laws and regulations.
7. Related UT Austin Policies, Procedures, Best Practices and Applicable Laws
The policies and practices listed here inform the system hardening procedures described in this document; you should be familiar with these documents. (This is not an all-inclusive list of policies and procedures that affect information technology resources.)
8. Revision History
Send computing questions to the ITS Help Desk or call (512) 475-9400.