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March 18, 2024
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 min read

Sensitive data Classification for HIPAA,PCI DSS, GDPR, ISO 27001 ,CCPA and More.

Discover the need for sensitive data classification to comply with major cyber compliance requirements like PCI DSS, HIPAA, GDPR, CCPA, ISO 27001, NIST 800-53, SOC 2.

Sensitive data Classification for HIPAA,PCI DSS, GDPR, ISO 27001 ,CCPA and More.
Calendar Icon White
March 18, 2024
Clock Icon
 min read

Sensitive data Classification for HIPAA,PCI DSS, GDPR, ISO 27001 ,CCPA and More.

Discover the need for sensitive data classification to comply with major cyber compliance requirements like PCI DSS, HIPAA, GDPR, CCPA, ISO 27001, NIST 800-53, SOC 2.


Data classification is key to meeting and demonstrating compliance across various regulations like PCI DSS, HIPAA, SOX, and GDPR. These standards, each with unique goals and demands, require the precise identification and labeling of regulated data—such as health records, cardholder data, and financial documents—to ensure its proper protection. This guide provides practical strategies for data classification tailored to the specific regulations and standards relevant to your organization.

What is Sensitive Data Classification?

Sensitive data classification is a critical process that involves categorizing data based on its level of sensitivity and the impact that its unauthorized disclosure could have on an organization or individuals. This foundational step in data protection helps businesses and organizations comply with various regulatory standards such as PCI DSS (Payment Card Industry Data Security Standard), HIPAA (Health Insurance Portability and Accountability Act), GDPR (General Data Protection Regulation), NIST (National Institute of Standards and Technology) frameworks, and ISO 27001. 

By identifying the types of data that are considered sensitive, such as personal identification information, financial records, health information, and confidential business information, organizations can implement appropriate security controls and compliance measures. 

This process not only safeguards the data from breaches and unauthorized access but also ensures that the organization meets legal and ethical obligations, thereby maintaining trust with clients, customers, and partners. 

Through sensitive data classification, organizations can effectively manage risks, prioritize security efforts, and align their data protection strategies with industry standards and regulations.

Challenges with Sensitive Data Classification for Regulatory Compliances

Many organizations find the constantly changing and complex compliance requirements difficult to navigate. Compliance officers often struggle with the rapid pace and sheer volume of regulatory updates as a primary challenge. Additionally, a significant skills gap exacerbates the issue, with 60% of cybersecurity experts citing a global shortage of cybersecurity talent as a risk to their organizations. 

Despite the widespread acknowledgment of data privacy as crucial to business, only 33% of security professionals prioritize data protection and governance as key responsibilities in their roles.

How Sensitive Data Classification Helps Comply With Regulatory Compliances?

Various laws and standards, specific to different industries and regions, mandate compliance regulations for data classification. 

The primary objective of these regulatory frameworks is to guarantee that organizations manage data with the utmost regard for privacy, security, and ethical considerations. Adherence to these regulations is essential for organizations to safeguard sensitive information, thereby preventing data breaches, avoiding legal consequences, and circumventing substantial financial penalties.

Moreover, compliance fosters trust among customers and stakeholders, as it showcases an organization's dedication to upholding data privacy and ensuring the security of personal and sensitive information. This commitment to compliance not only protects the organization but also reinforces its reputation as a trustworthy and responsible entity in managing data.

Data Classification for PCI DSS

The Payment Card Industry Data Security Standard (PCI DSS) was established to protect cardholder data across the globe. To comply, organizations are required to implement both technical and operational strategies to address vulnerabilities and enhance the security of payment card transactions.

What is payment card information?

Payment card information encompasses the credit card number (also known as the primary account number or PAN) when it is combined with any of the following elements:

  • Cardholder name
  • Service code
  • Expiration date
  • CVC2, CVV2, or CID value
  • PIN or PIN block
  • Information contained in the magnetic stripe of a credit card

What does PCI DSS require regarding data classification?

The process of data classification under PCI DSS entails the categorization of cardholder data elements based on their nature, storage allowances, and the level of protection they necessitate. Organizations are obligated to record all occurrences of cardholder data and verify that such data is not stored outside the designated cardholder data environment.

As reported in the Netwrix 2020 Data Risk and Security Report, 75% of financial institutions that undertake data classification are able to identify instances of data misuse within minutes. In contrast, those that do not classify data typically require days (43%) or even months (29%) to detect misuse. This statistic underscores the critical role of data classification in achieving PCI DSS compliance.

Let’s see how Strac does it

Data Classification for GDPR

Data inventory and classification play a pivotal role in ensuring compliance with the European Union’s General Data Protection Regulation (GDPR). Although the GDPR text does not explicitly mention "data inventory" or "mapping," these processes are indispensable for safeguarding personal data and establishing a data security program aligned with data privacy laws. 

For instance, conducting a data inventory is a fundamental step towards fulfilling the GDPR's mandate to keep records of processing activities. This involves identifying the categories of data, the purposes for which it is processed, and providing a general outline of the technical and organizational security measures in place.

Organizations are required to conduct a Data Protection Impact Assessment (DPIA) that encompasses all activities related to the collection, storage, utilization, or deletion of personal data. The DPIA should evaluate the significance or confidentiality of the data and the potential impact on privacy rights or distress that individuals might experience in the event of a security breach.

Which personal data is protected under the GDPR?

The GDPR protects personal data defined as any information that can be used to identify a natural person, either directly or indirectly. This includes, but is not limited to:

  • Name
  • Identification number
  • Location data
  • Online identifier
  • Factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of the person

What does GDPR require in terms of data classification?

Effective GDPR data classification necessitates organizations to take into account various aspects of the data, such as:

  • The type of data (e.g., financial, health)
  • The basis for its protection
  • The categories of individuals involved (e.g., customers, patients)
  • The categories of recipients, particularly when it involves international third-party vendors

Record-keeping for GDPR and ISO 27001 Framework

The record-keeping obligations under GDPR have substantial similarities with those outlined for ISO 27001 compliance. Therefore, adopting the ISO 27001 framework not only facilitates GDPR compliance but also ensures a robust approach to data management and security. By leveraging the structured processes and detailed record-keeping practices of ISO 27001, organizations can efficiently meet the GDPR requirements, thereby enhancing their data protection efforts and compliance posture.

Data Classification for ISO 27001

ISO/IEC 27001 is a globally recognized standard for creating, implementing, maintaining, and continually improving an Information Security Management System (ISMS). This standard, applicable to organizations of all types and sizes, aims to ensure the protection of information assets. When undergoing an ISO 27001 audit, organizations are expected to demonstrate a thorough understanding of their information assets, including their value, ownership, and the ways in which the data is used internally.

What types of data are protected under ISO 27001?

Unlike specific regulations that list exactly what data must be protected, ISO/IEC 27001 requires organizations to define the scope of their data environment themselves. This scope should take into account internal and external threats, the requirements of interested parties, and the interdependencies among the organization's operations. Therefore, it is the organization's responsibility to review all data within the defined scope to ensure comprehensive protection.

What does ISO 27001 require in terms of data classification?

Data classification is a fundamental aspect of ISO 27001 compliance. The standard mandates that organizations conduct an inventory of information assets and classify this information to ensure it receives an appropriate level of protection. Although ISO 27001 does not prescribe a specific policy for data classification under ISO 27011, it does provide guidance in section A.8.2 on how to approach this task:

  1. Classify data: Information should be classified in line with legal requirements, its value, and its sensitivity to unauthorized access or alteration. While the standard doesn't suggest specific classification levels, organizations typically adopt a scheme with levels such as Restricted, Confidential, and Public.
  2. Label data: Organizations are required to develop procedures for labeling information in accordance with their classification scheme. This includes labeling both digital and physical data, ensuring that the system is understandable and manageable.
  3. Establish handling rules: Based on the classification, rules must be set for how data is to be handled, including measures such as access control and encryption.

The flexibility of ISO 27001 allows organizations to tailor their data classification and protection strategies to their specific needs and risks, ensuring that information assets are appropriately secured against potential threats.

Data Classification for NIST 800-53

The National Institute of Standards and Technology (NIST) offers guidelines through Special Publication (SP) 800-53 for enhancing data security. This publication outlines security and privacy controls for federal information systems and organizations. It provides comprehensive advice on maintaining systems, applications, and integrations to safeguard the confidentiality, integrity, and availability of data.

NIST 800-53 is a mandatory framework for all federal agencies and their contractors but also serves as a valuable resource for private sector organizations.

What does NIST 800-53 require in terms of data classification?

NIST 800-53's approach to data classification categorizes information into three impact levels: low, moderate, and high. These levels are determined by the potential harm to agency operations, assets, or individuals that could result from a breach by either internal or external threats.

Each category—confidentiality, integrity, and availability—receives an impact value. The overall security impact level is then determined using the "high watermark" principle, meaning the highest impact level across confidentiality, integrity, and availability defines the final classification. Therefore, if any of the three criteria is assessed as high impact, the data's classification level is deemed high.

Which types of data are protected under NIST 800-53?

NIST 800-53 does not prescribe explicit classification levels for data as some standards do. However, NIST Special Publication 800-53 Rev. 5 includes categories such as:

  1. Classified Information: While NIST does not detail specific levels like Confidential, Secret, or Top Secret—since these are typically governed by separate government standards (e.g., Executive Order 13526)—it acknowledges the existence and necessity of such classifications.
  2. Controlled Unclassified Information (CUI): CUI is information that is not classified but still requires protection due to the risk it might pose to national security if disclosed improperly.  
  3. Unclassified Information: This category encompasses information that does not require special protection measures and is generally available for public access.

Additionally, NIST allows for the definition of other categories by organizations. For example, data related to "Planning and Budgeting" may include budget formulation and capital planning, which generally have a low impact on confidentiality, integrity, and availability. 

Yet, NIST advises organizations to consider special circumstances that could influence impact levels, like the early public release of budget drafts. This flexibility ensures organizations can tailor their classification to meet specific security requirements, aligning with NIST 800-53's overarching goal of protecting federal information systems while also offering guidance useful beyond government agencies.

Data Classification for HIPAA

The Health Insurance Portability and Accountability Act (HIPAA) Security Rule sets forth the administrative, physical, and technical safeguards required to protect the confidentiality, integrity, and availability of Protected Health Information (PHI). 

Electronic PHI (ePHI), which includes any PHI that is stored on or transmitted by electronic media, falls under this regulation. Electronic storage media encompasses computer hard drives and removable media such as optical disks and memory cards, while transmission media includes the internet or private networks.

PHI data classification encompasses a wide range of patient details, including but not limited to:

  1. Name
  2. Address
  3. Dates directly related to an individual (e.g., birth date, admission/discharge dates, or date of death), including the exact age if over 89
  4. Telephone or fax number
  5. Email address
  6. Social Security number
  7. Medical record number
  8. Health plan or insurance beneficiary number
  9. Vehicle identifiers and serial numbers, including license plate numbers
  10. Web URLs or IP addresses
  11. Biometric identifiers (e.g., fingerprints, voice prints, full-face photographs)
  12. Any other unique identifying number, characteristic, or code

What does HIPAA require in terms of data classification?

HIPAA mandates that organizations ensure the integrity of ePHI, protecting it against unauthorized alteration or destruction. Covered entities and business associates must inventory their ePHI to identify risks to its confidentiality, availability, and integrity. This involves pinpointing where the ePHI is stored, received, maintained, or transmitted, which can be achieved through reviewing past projects, conducting interviews, and examining documentation.

HIPAA data classification guidelines advise organizing data based on its sensitivity level. This classification helps determine the baseline security controls necessary for data protection. 

Organizations are recommended to adopt a three-tier data classification system:

  • Restricted/Confidential Data: This category includes data that, if disclosed, altered, or destroyed unauthorizedly, could result in significant harm. Such data demands the highest security measures and controlled access, adhering to the principle of least privilege.
  • Internal Data: Data in this category could cause low to moderate damage if disclosed, altered, or destroyed without authorization. Although not intended for public release, it requires adequate security controls.
  • Public Data: While public data does not require protection from unauthorized access, it still needs safeguards against unauthorized modification or destruction.

By classifying data into these categories, organizations can more effectively apply the necessary security controls to protect ePHI, in compliance with HIPAA requirements, thereby ensuring the privacy and security of sensitive health information.

Data Classification for SOX

The Sarbanes-Oxley Act (SOX), while not explicitly mandating data classification, underscores the importance of implementing stringent data classification practices as a means to achieve compliance. Classifying and securing sensitive financial data enables companies to strengthen internal controls, deter unauthorized access, and maintain the accuracy and integrity of financial information. These measures are central to meeting SOX compliance requirements.

What does SOX require in terms of data classification?

Effective data classification under SOX can facilitate compliance with several key sections of the Act:

  • Section 302: Corporate Responsibility for Financial Reports: This section mandates that the CEO and CFO personally certify the accuracy of financial reports. Data classification plays a crucial role here by helping organizations verify the reliability and accuracy of their financial information.
  • Section 404: Assessment of Internal Controls: Companies are required to establish and maintain adequate internal controls over financial reporting. Through proper data classification, organizations can discern which data necessitates specific levels of protection, thereby ensuring the integrity of financial reporting.
  • Section 802: Criminal Penalties for Altering Documents: This section addresses the illegal alteration, destruction, or concealment of records. Effective data classification is vital for identifying essential records and enforcing suitable controls to protect against unauthorized changes or deletions.

By categorizing financial data according to its sensitivity and significance, companies not only enhance their compliance with SOX but also bolster their overall financial data security framework. This systematic approach to data classification aids in pinpointing which data is critical for accurate financial reporting and requires stringent protective measures, ultimately supporting SOX's objectives of promoting transparency, accountability, and trust in the corporate and financial sectors.

Data Classification for SOC 2

SOC 2 (Service Organization Control 2) is a framework for managing data based on five trust service principles: security, availability, processing integrity, confidentiality, and privacy. While SOC 2 itself does not specifically mandate data classification, effectively implementing its principles necessitates a robust data classification system. By identifying and categorizing data according to its sensitivity and relevance to these principles, organizations can establish the necessary controls to ensure compliance with SOC 2 requirements.

What does SOC 2 require in terms of data classification?

Although SOC 2 does not lay out explicit guidelines for data classification, it implicitly requires organizations to undertake comprehensive measures to manage and protect data in line with the trust service principles. 

Data classification under SOC 2 involves several key actions:

  • Identify and categorize data: Organizations need to accurately identify and categorize data based on its importance and sensitivity concerning the SOC 2 principles. This categorization helps in applying appropriate security measures to different types of data, whether it's personal information, financial data, or operational information.
  • Implement security measures: SOC 2 emphasizes the need for stringent security measures to protect data. This includes encryption, access controls, and other security protocols designed to safeguard data from unauthorized access or disclosure. Effective data classification supports the implementation of these security measures by indicating which data requires more stringent protections.
  • Maintain confidentiality and privacy: For data related to the confidentiality and privacy principles, organizations must ensure that access is strictly controlled and that the data is handled in a manner that respects individual privacy rights. Data classification aids in identifying which data falls under these categories and establishing protocols for its protection.
  • Ensure availability and processing integrity: Data that is critical for the availability of services and the integrity of processing operations must be identified and protected accordingly. Classification helps determine the necessary measures to ensure that data is accurate, complete, and accessible when needed.
  • Demonstrate compliance: An effective data classification system is essential for demonstrating compliance with SOC 2. It enables organizations to document their data management practices and show auditors how data is categorized, protected, and managed in accordance with SOC 2 principles.

By systematically classifying data in alignment with the SOC 2 framework, organizations can more effectively apply the necessary controls to protect and manage data. This not only helps in achieving compliance with SOC 2 but also enhances the overall security and integrity of the organization's data management practices.

Data Classification for CCPA

The California Consumer Protection Act (CCPA) stands as a comprehensive privacy legislation designed to empower consumers with greater control over their personal information held by businesses. 

Although the CCPA does not specifically outline data classification protocols, it places a significant emphasis on the protection and categorization of consumer data. Effective data classification under the CCPA is crucial for compliance, allowing businesses to efficiently organize, manage, and protect the personal information they collect. 

By systematically categorizing data based on sensitivity, businesses can enhance their ability to identify, monitor, and secure personal information in alignment with CCPA requirements.

What does CCPA require in terms of data classification?

The CCPA mandates that organizations adopt strategies for the classification and management of personal data to ensure the protection of consumer privacy. While not prescribing specific data classification methodologies, the CCPA requires companies to perform several critical actions:

- Identify and categorize personal information: Businesses must accurately identify and categorize the types of personal information they collect, process, or store. This encompasses a wide range of data, including:

  • Names
  •  Addresses
  •  Social Security numbers
  •  Biometric data
  •  Geolocation data
  •  Online identifiers

- Implement security measures: To comply with the CCPA, organizations are tasked with deploying robust security measures to protect personal data. This may involve the use of encryption, access controls, and other security mechanisms to prevent unauthorized access to sensitive information.

- Uphold consumer rights: The CCPA endows consumers with several rights concerning their personal information. These rights include the ability to inquire about the data being collected, request the deletion of their data, and opt out of the sale of their information. Effective data classification facilitates the identification and management of data relevant to these rights, enabling organizations to fulfill consumer requests efficiently.

- Ensure transparency and accountability: Businesses are required to be transparent in their data practices and accountable for the manner in which consumer information is handled. Through data classification, organizations can document and demonstrate their data management processes and compliance efforts, supporting the CCPA's transparency and accountability objectives.

By adhering to these principles and implementing a thorough data classification system, businesses can navigate the requirements of the CCPA more effectively, ensuring that consumer data is managed with the highest standards of privacy and security.

Sensitive Data Discovery and Classification with Strac

Strac streamlines the process of identifying and managing sensitive data by automating the scanning and categorization of PII. This approach reduces manual effort and increases accuracy, ensuring sensitive information is consistently and correctly identified and addressed.

Sensitive Data Scanning: Strac conducts real-time scans on SaaS platforms like O365, Google Workspace, and Salesforce, and extends to cloud services and endpoint devices to detect and anonymize PII, ensuring extensive data protection.

Scanning for sensitive data in unstructured documents: Strac utilizes OCR (Optical Character Recognition) and specialized machine learning algorithms to search for sensitive information within unstructured documents of all types, including PDFs, JPEGs, PNGs (images/screenshots), DOCX (Word documents), and XLSX (Excel spreadsheets).

Unstructured Text Scanning: Strac employs its precise Machine Learning (ML) model to examine unstructured text, such as chat messages, transcripts, customer support dialogues, and email content, for the detection of sensitive information.

PII and PHI Remediation: Upon identifying sensitive data within your tools or storage, Strac automatically addresses these findings by implementing measures such as redaction, masking, encryption, deletion, alerts, or blocking. Companies have the flexibility to customize their data remediation strategies.

Founder, Strac. ex-Amazon Payments Infrastructure (Widget, API, Security) Builder for 11 years.

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