Classify This! 10 Best Practices to Jumpstart Your Data Classification Program By Mathew Schwartz
Many CIOs dream of applying automated classification to any data generated in
the enterprise. The overriding goal: to ensure the organization can apply more
of its scarce security resources to protecting its most sensitive data.
Keep dreaming: Outside of the government, few organizations report much
success with enterprise-wide information classification programs. “It’s a
cornerstone of information security, but it’s a project from hell. No one wants
to do anything about it,” says Nick Frost, senior research consultant for
Information Security Forum in London. Typical challenges include too many
classification schemas, overly manual processes, poor user buy-in - if not
outright resistance - as well as legacy data.
Why classify any data at all? Two words: legislation and regulations. Not to
mention a lingering feeling “by security professionals that they should be doing
this anyway,” says Frost. “But what certainly helped implement this was the
legal liability and penalties.” Those legal liabilities come via such
regulations as HIPAA, Safe Harbor, GLBA, the Protection Directive in Europe and
even stronger regulations in countries such as Germany.
But regulations are just the start. Other drivers include improving document
retention practices, data security, e-discovery, as well as operating
efficiency. According to Mark D. Rasch, managing director of technology for FTI
in Washington, D.C. and former lead prosecutor for the Department of Justice’s
computer crime cases, “if you don’t know what you’ve got, and how important it
is, you don’t know how long to keep it, and as a result, you tend to keep
everything, and that’s extremely costly in terms of storage as well as potential
data loss, and for litigation.”
Future technology may solve all of these issues by fully automating data
classification. But experts say those days are a good decade away. In the
interim, they offer these 10 tips for data classification:
1) Avoid “All or Nothing”
Thinking
Know that at the start, classifying everything will be impossible.
“It’s difficult for a lot of people in information security who come from
scientific or engineering backgrounds to accept that you’re not going to be able
to classify all of your information,” says Frost. As a result, many choose to
not classify anything at all. Avoid this kind of top-down, all-or-nothing
thinking. In fact, he says, the most successful organizations have introduced
data classification very slowly.
Even in mature programs, classification may still be used sparingly. “You can
say, we’ll just classify everything as sensitive, but that does no good,” says
Rasch. He dubs this the Yankee Stadium Syndrome: “when one person stands up,
they can see better, but when everyone stands up, no one can see better.”
2) Think Small
When starting out, “pick a small number of classification categories,”
recommends Fred Avolio, an 18-year computer and network security veteran
currently working for Johns Hopkins University, and make them easy to
understand. What are common categories? “For most companies, we are probably
talking about Company Confidential, Personnel Confidential, Client Confidential
and Restricted Distribution.” And do substitute the actual company name - “Acme
Corp. Confidential” - where appropriate.
3) Be Relevant
Naming classifications, however, is only the starting point. “You really need
to back it up with specific examples” that are relevant to any given group of
users, says Frost. As this implies, the exact meaning of classifications often
varies by business group, since “client confidential,” for example, naturally
means different things to sales, business development and IT teams.
4) Find Guinea Pigs
The best way to begin a data classification program is to find receptive
business groups. Human resources and the legal team are two likely candidates,
since they will be storing information governed by numerous regulations and
restrictions.
The next goal will be to advance beyond a “thou shalt classify” to a “how to
classify” culture. Armed services intelligence agencies do this particularly
well, says Frost. “In these military groups, they say they learn from their
colleagues - not just from the security professionals.”
5) Ignore the Past
When getting a data classification program up and running, of course there
will be old, unclassified data. Ignore it. Frost says companies with the most
successful data classification programs “start off classifying just what is
new.”
6) Follow Policies
“A common mistake is having a data classification policy and not following
it,” says Rasch. “I’d rather you not have a policy if you’re not going to do it,
because if you have a policy that says you have to do it and you don’t do it,
then you have double-trouble,” especially when it comes to data breaches,
e-discovery requests, litigation holds or a regulatory audit.
7) Track Requirements
Maintain a list of all classification drivers and their requirements. These
often include privacy laws, export restrictions, data retention requirements,
customer details and product-development information. “Many of these
classifications will overlap,” notes Rasch. “So you may have one document that
has multiple classifications on it, some of which expire and some of which may
continue. That’s what makes data classification more than trivial.”
8) Know Your Enemy
Data classification is not an abstract exercise. “Know your adversary,” says
Avolio. “Who is after your information? Who would benefit? What would an
adversary spend to get it? How much would an adversary benefit?”
Also beware of the so-called matrix theory, an espionage tactic “where if you
take enough benign information, you can learn a trade secret,” says Rasch. A
simple example: “You know A is talking to B, and B immediately talks to C, then
you know about relationships between people.”
9) Fine-Tune Penalties
Prepare for potential internal resistance. “You’re starting with the
assumption that people want to classify stuff. What do you do if they’re trying
to avoid it?” notes Rasch.
One technique for enforcing data classification used by some intelligence
agencies is to take a penalty approach, similar to a driver’s license model: Too
many incorrect data classifications, or a failure to classify classified data,
and the employee gets hit with points. Reach 12 points, and your security
clearance is downgraded. Meaning you’re probably out of a job.
10) Put Classifications to Work
Beyond using data classification to satisfy regulatory requirements, also
stress the business upsides to internal users. “Classifying information also
offers organizations a huge amount of opportunity,” says Frost. One example he
offers is a company that requires its employees to tag all “commercial”
(business-related) information. This designation is then added to the file
properties of relevant Word documents, Excel spreadsheets and e-mails.
Meanwhile, automated backup software trolls all hard drives, backing up files
tagged as “commercial” on a daily basis. Thus the company ensures it has current
backups of business-critical information, and tackles the rest - overwhelmingly,
personal e-mails, photos, and music - via monthly whole-disk backups.
Remember the Business Rationale
As the above strategies make clear, data classification mostly remains a
manual endeavor. Yet it need not be overly complex to be successful. Indeed,
with a little user buy-in, even a small information classification program can
have a big business upside.
Mathew Schwartz is a freelance business and technology journalist who
regularly covers IT, information security, and compliance trends.
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