Components Security Core Requirements Data Protection - DevClusterAI/DOD-definition GitHub Wiki

Data Protection

Data protection encompasses the policies, procedures, and technical controls to safeguard sensitive information throughout its lifecycle. This document outlines the data protection requirements that must be met as part of the Definition of Done.

Purpose

The purpose of these data protection requirements is to:

  • Ensure sensitive data is properly identified and classified
  • Implement appropriate controls to protect data based on its sensitivity
  • Comply with relevant data protection regulations and laws
  • Prevent unauthorized access, use, disclosure, or destruction of data
  • Establish clear data handling procedures across the organization

Data Classification

All data must be classified according to its sensitivity level:

Public Data

  • Information that can be freely disclosed to the public
  • No significant impact if disclosed
  • Examples: Marketing materials, public-facing documentation, open-source code

Internal Data

  • Information intended for use within the organization but not sensitive
  • Minimal impact if disclosed
  • Examples: Internal procedures, non-sensitive internal communications, general business information

Confidential Data

  • Sensitive information with restricted access
  • Moderate impact if disclosed
  • Examples: Financial information, internal strategy documents, employee data, certain customer data

Highly Confidential Data

  • Extremely sensitive information with strictly limited access
  • Severe impact if disclosed
  • Examples: Authentication credentials, encryption keys, personally identifiable information (PII), payment card information, health information

Data Protection Requirements by Classification

All Data Classifications

  • Regular backup and recovery procedures must be implemented
  • Data retention periods must be defined and enforced
  • Secure deletion procedures must be implemented when data reaches end of retention period
  • Regular data quality assessments must be performed

Internal Data

All requirements for Public Data, plus:

  • Access restricted to authenticated users
  • Basic access controls implemented
  • Data transfers must be logged

Confidential Data

All requirements for Internal Data, plus:

  • Strong access controls with role-based permissions
  • Encryption of data at rest recommended
  • Encryption of data in transit required
  • Detailed access logs maintained
  • Regular access reviews performed
  • Data Loss Prevention (DLP) monitoring

Highly Confidential Data

All requirements for Confidential Data, plus:

  • Strong encryption of data at rest required
  • End-to-end encryption for data in transit required
  • Multi-factor authentication for access
  • Strict need-to-know access controls
  • Enhanced monitoring and alerting
  • Regular penetration testing of protective controls
  • Data anonymization or pseudonymization where possible

Data Protection Processes

Data Inventory and Classification

  • All data repositories must be inventoried
  • Data flows must be documented
  • Data must be classified according to defined criteria
  • Classifications must be regularly reviewed and updated

Access Control Management

  • Access must be granted based on the principle of least privilege
  • Regular access reviews must be conducted
  • Strong authentication and authorization controls must be implemented
  • Privileged access must be strictly controlled
  • Access revocation processes must be timely and comprehensive

Data Encryption

  • Industry-standard encryption algorithms must be used
  • Cryptographic keys must be securely managed
  • Key rotation procedures must be implemented
  • Encryption implementation must be regularly reviewed
  • Hardware Security Modules (HSMs) should be used for critical operations

Data Handling Procedures

  • Clear procedures for data creation, storage, use, sharing, archiving, and destruction
  • Secure file transfer protocols must be used
  • Mobile device protection measures must be implemented
  • Secure development practices for data handling
  • Clear desk and clear screen policies

Data Breach Response

  • Data breach detection capabilities must be implemented
  • Incident response procedures must be defined
  • Notification procedures must comply with relevant regulations
  • Regular testing of breach response procedures
  • Post-breach analysis and improvement process

Regulatory Compliance

Data protection measures must address requirements from relevant regulations, including but not limited to:

  • General Data Protection Regulation (GDPR)
  • California Consumer Privacy Act (CCPA)
  • Health Insurance Portability and Accountability Act (HIPAA)
  • Payment Card Industry Data Security Standard (PCI DSS)
  • Other applicable local, national, and international regulations

Definition of Done Criteria

For data protection to meet the Definition of Done, the following criteria must be satisfied:

  • Data handled by the application has been properly classified
  • Data protection controls appropriate to the classification have been implemented
  • Data protection impact assessment has been completed when required
  • Privacy by design principles have been applied
  • Regulatory compliance requirements have been addressed
  • Data protection measures have been tested and validated
  • Data protection documentation has been updated

References

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