How to
Establish and Maintain a Data Management Process
- SafeGuard 3.1
Here's a step-by-step guide to establishing and maintaining a data management process that addresses data sensitivity, data ownership, handling, retention, and disposal requirements based on sensitivity and retention standards for the enterprise, as per the requirements in CIS Control 3 - Data Protection, Implementation Group 1 (IG1):
Step 1: Define Data Management Policies:
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Define policies that outline how data should be managed, based on its sensitivity and retention requirements.
Step 2: Data Sensitivity Classification:
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Classify data based on its sensitivity level, such as public, internal, confidential, and highly confidential. Assign sensitivity labels to each category.
Step 3: Identify Data Owners:
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Identify data owners or custodians responsible for each data category. Data owners are accountable for managing the data's lifecycle.
Step 4: Data Handling Guidelines:
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Develop guidelines for the handling of each data category, specifying who can access, modify, or share the data, and under what circumstances.
Step 5: Data Retention Policies:
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Define data retention periods for each data category based on legal, regulatory, and business requirements. Determine when data should be archived or deleted.
Step 6: Data Disposal Requirements:
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Establish procedures for securely disposing of data at the end of its retention period. This could involve shredding physical documents or securely deleting electronic data.
Step 7: Data Storage and Encryption:
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Determine how data should be stored and protected, including encryption and access controls, based on its sensitivity.
By following these steps, you'll establish a comprehensive data management process that addresses data sensitivity, ownership, handling, retention, and disposal, aligning with the requirements of CIS Control 3.
Step 8: Documentation of the Data Management Process:
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Document the entire data management process, including policies, data classification criteria, data owner roles, handling guidelines, retention periods, and disposal procedures.
Step 9: Communication and Training:
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Communicate the data management process to relevant stakeholders and provide training on their roles and responsibilities within the process.
Step 10: Annual Documentation Review:
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Review and update the data management process documentation annually to ensure it remains accurate and relevant.
Step 11: Changes in Enterprise:
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Revisit the documentation when significant changes occur within your organization, such as technological changes, structural changes, or shifts in data requirements.
Step 12: Incident Response Integration:
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Integrate the data management process with your incident response plan to ensure proper handling of data during incidents.
Step 13: Continuous Improvement:
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Continuously assess and improve the data management process based on feedback, lessons learned, and changes in regulations or data sensitivity.
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By following these steps, you'll establish a comprehensive data management process that addresses data sensitivity, ownership, handling, retention, and disposal, aligning with the requirements of CIS Control 3. This process enhances your organization's data security, incident response capabilities, and overall compliance efforts.