Data Classification and Labeling Policy - SME

The Data Classification and Labeling Policy (P13S) defines how all information handled by the organization must be classified and labeled, ensuring its confidentiality, integrity, and availability throughout its lifecycle. This policy enables consistent and compliant data handling by assigning protection levels to information based on sensitivity, business impact, or legal obligations, such as those defined by GDPR, NIS2, and DORA. Its adoption is critical for organizations seeking ISO/IEC 27001 certification, enabling them to systematically reduce the risk of accidental disclosure, unauthorized access, or mishandling of sensitive data. Notably, this is an SME policy, as indicated by its P13S document number and the assignment of 'General Manager' as the policy owner, reflecting adaptation for organizations without dedicated IT or CISO roles. The policy translates complex regulatory and security requirements into clearly structured responsibilities suitable for SMEs. The General Manager owns and oversees policy enforcement and exceptions; Information Owners or Data Managers handle initial classification, labeling, and periodic review; the IT Lead or Administrator (internal or outsourced) implements technical controls; and all staff/contractors are required to apply, check, and respect classifications while participating in training. The scope of the policy is comprehensive, spanning all organizational data regardless of format, location, or lifecycle stage. This includes electronic files, cloud and on-premises data, physical documents, emails, and even temporary or transitory data like logs and cache files. Staff and third parties handling such data must consistently apply classification and labeling throughout creation, use, storage, transfer, archival, or deletion. A simple three-level classification scheme is required: Public (openly shareable), Internal (restricted to staff), and Confidential (sensitive, requiring strictest protection measures such as encryption and controlled access). The policy mandates visible and persistent labeling across digital and physical assets, routine reviews when business models, software, or legislation change, and formal handling rules for each classification level. These provisions ensure that SMEs, even with simplified operational structures, can demonstrate legal compliance and risk-based data protection, while fostering accountability and clear data stewardship. Periodic audits, spot checks, and documented exception management further reinforce compliance. Violations, such as storing confidential data in unsecured locations or failing to label assets appropriately, are subject to sanctions ranging from warnings to legal action. The annual mandatory review ensures the policy adapts to evolving risks, regulatory demands, and organizational changes, making it an integral component of a defensible SME cybersecurity and privacy program.