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The Data Classification and Handling Guidelines establishes Oakleaf’s framework for protecting information based on a four-level classification scheme: Restricted, Confidential, Private, and Public. Each classification reflects the sensitivity of the data and prescribes specific handling and security controls to minimize risks.

1. <strong>Restricted Data</strong> is the most sensitive, often subject to legal or contractual constraints (e.g., Personally Identifiable Information (PII), Non-Public Information (NPI), loan files). Unauthorized disclosure can cause significant damage including reputational harm, legal penalties, or competitive disadvantage. Handling requires strict encryption, limited access, prohibition on mobile/cloud storage, encrypted transmissions, restricted printing, and CEO/CISO approval for third-party sharing.

2. <strong>Confidential Data</strong> includes highly valuable internal information like employee PII, accounting, payroll, and financial data. Loss could moderately impact Oakleaf’s reputation or contractual obligations. It requires encryption for storage and transmission, access controls, restricted printing and faxing, and approval for third-party disclosures with recommended NDAs.

3. <strong>Private Data</strong> is internally generated or entrusted information that should not be public but poses minimal damage if exposed. Recommended controls include encryption for mobile storage, logical access restrictions, and NDA recommendations for third parties. Handling is less stringent but still emphasizes secure disposal and controlled access.

4. <strong>Public Data</strong> can be freely shared without damage or risk. There are minimal handling requirements, mainly standard labeling and orderly disposal.

The guidelines also define Personally Identifiable Information (PII) and Non-Public Information (NPI) as data containing a person’s name along with elements like Social Security numbers, driver’s licenses, financial account numbers, and protected health information.

Oakleaf’s policies require applying the most restrictive classification when combining multiple data types, prohibiting down-classifying data formats unless equivalent controls exist, and documenting exceptions only with CEO/CISO approval. The document includes detailed examples of classified data types and prescribes labeling and packaging standards for both electronic and hardcopy media. Compliance with client-specific data handling requirements is also emphasized.

This policy, approved by Oakleaf’s CEO and CISO, aligns with ISO 27002 and NIST standards and is subject to periodic revision and internal audits.
Keywords
Data Classification
Restricted Data
Confidential Data
Private Data
Public Data
Personally Identifiable Information (PII)
Non-Public Information (NPI)
Data Handling Guidelines
Oakleaf Security Policy
ISO 27002 and NIST Compliance