Non-Technical Controls for Securing Data
Governance – Protecting data with policies and procedures
Classification of data
Applies to existing and new data
Intellectual property:
Public
Private
Restricted
Confidential
Military version:
Unclassified
Classified
Confidential
Secret
Top Secret
Review classification periodically:
Changing jurisdictions
Data “ages” over time
Data Types
Requirements stem from regulations: PII, PHI, financial data
Types are usually built into DLP solutions
Types include non digital media as well
Data Ownership
Data Owner
CIA of data
Labels of data
Org can be owner
Data steward
Handles data quality
Labelling and classification
Proper collection and storage
Data custodian
Handles the system that stores the data
Access control, encryption, backups
Privacy Officer
Handles privacy
PII, PHI handled correctly
Legal requirements
GDPR
SOX
PCI-DSS
GLBA
FISMA
COSO
HIPAA
Purpose Limitation
Data minimization
Data sovereignty
Retention: e-discovery
Policies and Procedures: short term and long term
Data sharing
Service Level Agreement
NDA
MOU – Gentleman’s agreement. Non legally binding.
ISA – interconnection security agreement – for federal agencies
Data sharing and use agreements
Security, privacy, and governance. Know the difference.
Access Control
Data dissemination
Retention or destruction
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