Every organization needs a solid set of policies and procedures to properly manage and protect their data throughout its entire lifecycle. These policies should cover data classification, acceptable use, retention, disposal, and the roles and responsibilities of data stewards. Procedures need to specify the technical controls used to enforce the policies and protect data in each phase - processing, storage, and transmission.
Where did this come from?
This control comes from the CSA Cloud Controls Matrix v4.0.10 released on 2023-09-26. You can download the full CCM spreadsheet from the Cloud Security Alliance website.
The DSP-01 control maps to several other industry standards and regulations related to data privacy and security:
- AICPA TSC 2017 CC1.1
- ISO/IEC 27001:2013 5.1.1, 5.1.2, A.5
- NIST SP 800-53 R5 AC-1
- NIST SP 800-171 R2 3.1.1, 3.1.2, 3.1.3
For more background, check out the NIST Privacy Framework which provides additional guidance on managing privacy risk.
Who should care?
Several roles should be concerned with this control:
- Chief Information Security Officers (CISO) responsible for overall data protection
- Chief Privacy Officers (CPO) overseeing privacy compliance
- Data Owners who are accountable for specific datasets
- Compliance Officers ensuring the organization adheres to applicable laws and regulations
- IT Administrators implementing the technical controls
- All Employees who handle sensitive data as part of their job
What is the risk?
Without clear policies and procedures, sensitive data could be mishandled leading to:
- Unauthorized access or disclosure of private customer data
- Non-compliance with data privacy regulations like GDPR, CCPA, etc.
- Reputational damage from public data breaches
- Financial losses from ransom demands, lawsuits, fines
While policies alone can't prevent all incidents, they are a critical foundation. Well-defined and enforced policies can significantly reduce the likelihood and impact of data breaches.
What's the care factor?
For any company dealing with private customer data, this should be a top priority. The consequences of poor data handling are severe - potentially irreparable harm to brand trust, huge financial penalties, even criminal charges for executives.
All employees should care deeply about properly managing any data they interact with. However, ultimate responsibility sits with senior leadership to set the right tone and ensure policies have teeth.
When is it relevant?
Formal data policies are essential for:
- Organizations operating in regulated industries like healthcare, finance, government
- Cloud service providers handling customer data
- Companies with large customer databases
- Global firms dealing with data across borders
Smaller businesses with minimal sensitive data may not need such rigorous policies. However, basic data hygiene is important for everyone.
What are the trade-offs?
Implementing robust data policies takes significant time and resources:
- Classifying huge volumes of legacy data
- Deploying DLP and access control tools
- Training all staff on policies
- Enforcing compliance and handling violations
- Keeping policies and procedures current
Strict controls can also impact productivity and user experience if not well designed. Finding the right balance between security and business needs is key.
How to make it happen?
- Assign ownership:
- Appoint a senior leader (CISO/CPO) to oversee the data protection program
- Identify data owners for each major dataset
- Discover data:
- Inventory all data assets across the organization
- Determine what types of data are collected, where it's stored, how it flows
- Assess risk:
- Evaluate the sensitivity and criticality of each dataset
- Consider risk of unauthorized access, corruption, loss for each
- Develop policies:
- Define clear data classifications (public, private, restricted, etc.)
- Specify acceptable use and handling requirements per classification
- Set retention periods and disposal procedures
- Assign roles and responsibilities
- Implement controls:
- Deploy technical tools to enforce policies (access control, DLP, encryption, etc.)
- Document how controls map to policy requirements
- Train users:
- Educate all staff on the policies relevant to their role
- Provide clear examples of acceptable and unacceptable behaviors
- Monitor and audit:
- Regularly review logs to identify potential violations
- Perform periodic audits to assess control effectiveness
- Commission third-party assessments for critical policies
- Improve and evolve:
- Adjust policies and procedures based on audit findings
- Stay up to date with changing laws and threat landscape
- Review and update at least annually
What are some gotchas?
- Classification can be subjective. Provide clear definitions and examples.
- Access control tools need all relevant permissions (IAM, bucket policies, KMS policies, etc.)
- DLP tools can disrupt legitimate data flows if rules are too broad. Tune carefully.
- Encrypting data at rest requires proper key management. Consider AWS KMS.
- Data destruction requires secure wiping, not just deletion. Use DOD 5220.22-M techniques.
- Shared responsibility model applies. Cloud providers only cover their scope.
What are the alternatives?
Some organizations try to protect data without formal policies. This is unwise given the stakes involved today. Tackling this ad-hoc will inevitably lead to gaps and inconsistency.
Others may simply adopt a generic policy template. While this is better than nothing, vague hand-wavy policies are not a substitute for well-tailored ones that reflect the organization's particular data, risks and culture.
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