Template draft. Replace everything in [square brackets] with your own decision,
delete what does not describe what you really do, and approve it through your own document control. It is not legal
advice and does not make an organisation compliant or certified.
1. Purpose
This procedure turns the Information Classification and Handling Policy into daily practice. It tells every person how to decide which classification level applies to a piece of information, how to mark it so the level is visible, how to store, share, print, carry and transmit it, and how to destroy it, together with the media that held it, when it is no longer needed.
It is written so that a new joiner can follow it without asking for help, and so that an auditor can pick any step and find the evidence that it was performed.
2. Scope
The procedure applies to all information created, received, processed, stored or transmitted by or for the Organisation, in any form: electronic files, email and messages, databases, paper, removable media, recordings, images, and information held in people's memory when it is repeated in writing or speech.
- In scope: employees, contractors, interns, consultants and suppliers who handle Organisation information; all Organisation-owned and approved personal devices; all locations, including home and travel; all cloud services holding Organisation information.
- In scope: all media that holds information, including laptops, servers, storage arrays, backup media, removable drives, mobile devices, printers and multifunction devices with storage, and paper.
- Out of scope: information that is already public by lawful release and has been recorded as such in the classification register; personal information of an individual that has no connection with the Organisation, even if it is held on an Organisation device.
3. Terms and Definitions
| Term | Meaning |
|---|
| Information owner | The named role accountable for a set of information and for deciding its classification, who may access it and how long it is kept. |
| Custodian | The person or team that holds or processes information on behalf of the owner, such as IT operations or a supplier. |
| Classification level | One of the four labels [Public, Internal, Confidential, Restricted] that states how much protection information needs. |
| Label | A visible or machine-readable mark that shows the classification level of an item. |
| Media | Any physical or logical container of information, including disks, tapes, flash drives, paper and cloud storage volumes. |
| Sanitisation | Making information on media unrecoverable by a stated method such as overwrite, cryptographic erase, degauss or physical destruction. |
| Need to know | The principle that access is limited to those who require the information to do their authorised work. |
4. Roles and Responsibilities
| Role | Responsibilities |
|---|
| Document owner (Head of IT Security) | Maintains this procedure, the classification matrix and the labelling templates; reports exceptions and measures to the ISMS steering group [quarterly]. |
| Information owner | Classifies information within [5 working days] of creation or acquisition, approves access, reviews the classification [annually] and approves release outside the Organisation. |
| Custodian (IT operations) | Applies the technical controls required for the level, including encryption, access lists, logging and secure erase, and keeps disposal records. |
| Line managers | Make sure their teams know the levels, correct mislabelled items and approve the removal of Confidential or Restricted material from premises. |
| All users | Label what they create, handle it according to its level, report loss or exposure within [1 hour] of noticing, and never downgrade a label without the owner's approval. |
| Data protection officer | Confirms the level of any item containing personal data and advises on lawful transfer and retention. |
| Facilities and administration | Operate secure shredding, locked disposal bins and the physical media store. |
| Suppliers and contractors | Follow the handling rules written into their contract and return or destroy information at the end of the engagement with written proof. |
| Activity | Responsible | Accountable | Consulted | Informed |
|---|
| Classify new information | Information owner | Information owner | Data protection officer | Custodian |
| Maintain the classification matrix | Head of IT Security | Head of IT Security | Information owners | All users |
| Apply technical protection for a level | Custodian | Head of IT Security | Information owner | Line manager |
| Release information to a third party | Information owner | Information owner | Legal, data protection officer | Head of IT Security |
| Sanitise or destroy media | Custodian | Head of IT Security | Information owner | Asset manager |
| Investigate mishandling | Head of IT Security | Chief Information Security Officer | HR, legal | Line manager |
5. Classification Levels
Every item takes the level that matches the worst outcome if it were disclosed, altered or lost. Where one document contains parts at different levels, the whole document takes the highest level until the parts are separated.
| Level | Description | Examples | Impact if exposed |
|---|
| Public | Approved for release to anyone. | Published website content, marketing brochures, job advertisements. | None to negligible. |
| Internal | For use by the workforce and trusted suppliers only. | Internal policies, staff directory, meeting notes, project plans. | Minor embarrassment or loss of efficiency. |
| Confidential | Business information whose disclosure harms the Organisation or its customers. | Customer contracts, financial results before release, source code, personal data, audit reports. | Financial loss, contractual breach, legal exposure, loss of trust. |
| Restricted | Information limited to named individuals, whose exposure would cause severe harm. | Encryption keys, credentials, security incident forensics, merger plans, special categories of personal data. | Serious legal or financial harm, threat to individuals, threat to business survival. |
Note. When in doubt, label the item [Confidential] and ask the information owner or the Head of IT Security to confirm within [2 working days]. Do not leave an item unclassified.
6. Classification Procedure
- Identify the ownerThe creator or the receiving team names the information owner. If the item is received from outside, the recipient's line manager is the owner until reassigned. Target: at creation or receipt.
- Assess impactAsk what would happen if the item became public, changed without notice, or were unavailable for [one day]. Consider customer, legal, contractual and personal data effects. Use the classification matrix in this procedure.
- Assign the levelChoose the highest level that applies. Record it for any collection of items in the classification register (Annexure A). Target: within [5 working days].
- LabelApply the label as described in the labelling rules below before the item is stored or shared.
- ReviewOwners review levels [annually] and when the item changes purpose, is shared in new ways, or after an incident. Downgrade only when the sensitivity has demonstrably ended, for example after public announcement.
7. Information Labelling
A label must be visible to a person at the time of use and, where possible, readable by tools such as data loss prevention and email gateways. The label wording is exactly one of the four level names.
7.1 Labelling by format
| Format | How to label | Who does it |
|---|
| Documents and presentations | Level in the header or footer of every page, and in the file properties where the tool supports it. Use the approved template. | Author |
| Spreadsheets and exports | Level on the first sheet and in the file name suffix, for example [_CONF] for Confidential. | Author |
| Email | Level in the subject prefix, for example [Confidential], for Confidential and Restricted messages; Internal is the default and needs no tag. | Sender |
| Databases and data stores | Level recorded in the asset register and in the schema or storage tag; reports printed from them carry the level of the data shown. | Custodian |
| Source code repositories | Repository visibility and a level statement in the readme. | Repository owner |
| Removable media and tapes | Adhesive label with level, asset identifier and owner's initials. Encrypted media is marked as such. | Custodian |
| Paper | Stamp or print the level on the top and bottom of each page; sealed envelopes carry the level and addressee on the outside. | Author or sender |
| Cloud folders and collaboration spaces | Level in the space name or description and a sensitivity tag where the platform allows. | Space owner |
| Physical items and devices | Asset tag; the level of information held is in the asset register. | Asset manager |
7.2 Labelling rules
- Unlabelled information is treated as [Internal] for reading and as [Confidential] for sharing outside the Organisation until the owner confirms.
- When extracts from several items are combined, the new item takes the highest level among them.
- A label may be raised by anyone who sees the need; it may be lowered only by the information owner, with a note in the register.
- Do not put the level in a form that discloses sensitive content, such as a file name containing a customer's personal details.
- Information received from a customer or partner keeps the label they applied and is also mapped to the nearest level in this procedure; the stricter of the two applies.
- Where labelling is impractical, such as for streaming logs or machine-to-machine data, the level is set at system level and recorded in the asset register.
8. Information Handling
The matrix below sets the minimum handling for each level. Where a customer contract or applicable law demands more, the stricter rule applies.
| Activity | Public | Internal | Confidential | Restricted |
|---|
| Storage on file shares and cloud | Any approved location. | Approved company locations; access by role. | Approved locations with named-group access and encryption at rest. | Dedicated secured location, named individuals only, encryption at rest, access logged and reviewed [monthly]. |
| Storage on laptops and phones | Allowed. | Allowed on managed devices. | Only on managed devices with full-disk encryption. | Not stored locally unless the owner approves in writing; if so, encrypted container and time limit of [30 days]. |
| Removable media | Allowed. | Allowed on approved media. | Encrypted approved media only; owner approval. | Not permitted except with written approval from the Head of IT Security. |
| Email and messaging | No restriction. | Company email and approved chat. | Company email to named recipients; encrypted or access-controlled link for external recipients. | Only through the approved secure transfer tool; never by chat or personal email. |
| External sharing | Free. | With a business reason and recipient who is under confidentiality duty. | Owner approval and signed confidentiality terms or contract clause. | Owner and Head of IT Security approval, encrypted, logged in the transfer register. |
| Printing | Free. | Allowed in the office. | Secure print with badge release; collect at once. | Only with owner approval; numbered copies, logged. |
| Working away from the office | Free. | Allowed on managed devices and secure networks. | Allowed on managed devices, screen privacy used in public, no printing at home. | Only in approved locations and on approved devices. |
| Verbal discussion | Free. | Not in public places. | Private rooms; no speakerphone in open areas. | Closed rooms with no devices that record, attendees listed. |
| Retention and deletion | As per business need. | Per retention schedule. | Per retention schedule; deletion evidence kept. | Per retention schedule; certified sanitisation of media. |
8.1 Handling expectations for everyone
- Collect printouts immediately and never leave Confidential or Restricted paper on a printer, desk or meeting room table.
- Do not discuss Confidential or Restricted information in lifts, cafes, public transport or on open video calls.
- Before sending, check recipients, attachments and the level label; use delayed send or recipient confirmation for external Confidential email.
- Share by access-controlled link with an expiry in preference to attachments, and remove access when the work ends.
- Keep Restricted information out of test and development environments; if copies are required, mask or substitute the data.
- Report any suspected loss, exposure or sharing in error to the service desk within [1 hour]. Do not attempt to retrieve or delete without advice.
8.2 Transfer outside the Organisation
- RequestThe sender states recipient, purpose, items, level and method in the transfer register (Annexure B) for Confidential and Restricted items.
- ApproveThe information owner approves; for Restricted, the Head of IT Security also approves. Target: [1 working day].
- ProtectEncrypt the item with an approved method and send the passphrase or key through a different channel from the data.
- ConfirmAsk the recipient to acknowledge receipt and the expected handling. Record the acknowledgement.
- CloseRemove temporary links and copies after [30 days] or when the purpose ends, whichever is earlier.
9. Information and Media Disposal
Information is disposed of when its retention period in the Documents and Records Management Procedure ends, when the business purpose ends, or when a customer or law requires deletion. Media is sanitised before it is reused, repaired by a third party, returned to a lessor or discarded. The detailed asset side of this is in the Asset Disposal Process.
9.1 Disposal methods by media
| Media | Approved method | Evidence |
|---|
| Paper | Cross-cut shredding on site or in locked bins collected by an approved contractor; pulping or incineration for Restricted. | Shredding log or contractor certificate. |
| Hard disks (magnetic) | Verified overwrite with [three passes] or cryptographic erase for encrypted disks; physical destruction if the disk has failed or held Restricted data. | Tool report or destruction certificate with serial number. |
| Solid state drives and flash | Cryptographic erase or the manufacturer's secure erase command, followed by verification; physical destruction for failed devices. | Tool report or certificate. |
| Removable media (USB, SD, optical) | Physical destruction by shredding or crushing; flash media may be securely erased if reused internally. | Disposal record. |
| Backup tapes and cartridges | Degauss then destroy, or encryption key destruction where all data is encrypted with a dedicated key. | Media destruction record. |
| Mobile devices | Remote wipe, factory reset after removing accounts, then secure erase or destruction at retirement. | MDM wipe log and asset record update. |
| Printers and multifunction devices | Remove or erase the internal storage before return or sale. | Technician's sign-off. |
| Cloud storage and SaaS data | Delete data and backups through the service, then obtain the supplier's written confirmation; destroy the keys held by the Organisation. | Supplier confirmation and key destruction record. |
| Virtual machines and containers | Delete disks and snapshots, and wipe the underlying volumes or retire their keys. | Change record. |
9.2 Disposal procedure
- IdentifyThe custodian lists the items due for disposal from the asset register or the retention schedule. Input: asset list or expiry report.
- Check holdsThe owner confirms there is no legal, audit, investigation or contract hold on the items. A hold stops disposal. Target: [3 working days].
- SecureStore the items in a locked cage or cabinet marked for disposal until collection; keep a custody sheet.
- SanitiseApply the method in the table. For third-party destruction, use an approved vendor under contract and witness or record collection.
- VerifyA second person checks a sample of sanitised items, or the full set for Restricted, and signs the disposal record (Annexure C).
- RecordUpdate the asset register to Disposed, attach certificates, and keep the record for [3 years].
9.3 Rules for disposal
- Media that held Confidential or Restricted information never leaves Organisation control until it has been sanitised or destroyed.
- Sanitisation by a supplier is allowed only where the contract requires approved methods, personnel vetting, chain of custody and a certificate.
- Devices sold, donated or re-issued internally are sanitised and re-imaged first; a new user must never see the previous user's data.
- Information in recycle bins, shared drives, chat history and personal drives is deleted according to the retention schedule, not left to accumulate.
- Personal data is deleted when its purpose ends, and the deletion is recorded so that a data subject request can be answered. See the Data Protection and Privacy Procedure.
10. Measures
| Measure | Target | How measured |
|---|
| Information assets with a recorded owner and level | [95 percent] | Count in the classification register against the asset register. |
| Sample of documents correctly labelled | [90 percent] | [Quarterly] sample of 30 documents by IT security. |
| Disposal certificates on file for sanitised media | [100 percent] | Disposal register compared with certificates. |
| Mishandling incidents reported within 1 hour | [90 percent] | Incident register timestamps. |
| External transfers of Confidential and Restricted items in the transfer register | [100 percent] | Gateway log sample against the register. |
| Classification reviews completed on time | [90 percent] | Register review dates. |
11. Records and Evidence
| Record | Kept by | Retention |
|---|
| Classification register | Information owners; consolidated by IT security | [Life of the asset plus 1 year] |
| Transfer register | IT security | [3 years] |
| Disposal records and certificates | Asset manager | [3 years] |
| Labelling exceptions and downgrades | IT security | [3 years] |
| Mishandling incidents and outcomes | IT security | [3 years] |
Annexure A: Classification register
| Information set | Owner | Custodian | Level | Basis for level | Date assigned | Next review |
|---|
| | | | | | |
| | | | | | |
Annexure B: External transfer register
| Date | Sender | Recipient and organisation | Items and level | Method and encryption | Approver | Acknowledged on |
|---|
| | | | | | |
| | | | | | |
| Asset or serial | Media type | Level held | Method | Performed by | Verified by | Date | Certificate reference |
|---|
| | | | | | | |
| | | | | | | |
12. Exception
Exceptions to this document are allowed only where compliance is not practicable and the risk has been assessed. A request must state what is to be excepted, why, the risk it creates, the compensating controls, and an end date no later than [6 months]. It is approved in writing by the document owner and the risk owner, recorded in the exceptions register, and reviewed at the end date. An exception does not change the document.
13. Enforcement
Compliance is monitored through internal audits, management review and routine checks by the document owner. Non-compliance is reported through the incident or non-conformity process and handled under the organisation's disciplinary procedure, and under the terms of any contract for people who are not employees. Serious or repeated non-compliance may lead to loss of access and, where the law is broken, to referral to the authorities.
14. Review
This document is reviewed at least every [12 months], and when there is a significant change to the organisation, its systems, its risks or the law, or after an incident that shows it was not effective. Each review is recorded in the revision history.
ISO/IEC 27001:2022 references
| Reference | Title |
|---|
| A.5.12 | Classification of information |
| A.5.13 | Labelling of information |
| A.5.14 | Information transfer |
| A.7.10 | Storage media |
| A.7.14 | Secure disposal or re-use of equipment |
| A.8.10 | Information deletion |