dataVersion 1SOC2ISO27001NIST800-171GDPR
Data Classification & Handling Policy
How data is classified and what handling rules apply to each level.
Data Classification & Handling Policy
1. Purpose
Establishes the classification scheme Rex Black uses to decide how every piece of data must be stored, transmitted, shared, and destroyed.
2. Classification scheme
| Level | Definition | Examples |
|---|---|---|
| Public | Approved for public release. | Website marketing content, published policies, open-source code. |
| Internal | Non-sensitive business data; disclosure is undesirable but not harmful. | Internal wikis, PRs, project plans. |
| Confidential | Sensitive business or client data; disclosure causes material harm. | Executed SOWs, client project data, internal finances, source code. |
| Restricted | Legally protected data; disclosure triggers regulatory duties. | PII, PHI, payment card data, authentication secrets, CUI, export-controlled. |
3. Handling requirements by level
| Control | Public | Internal | Confidential | Restricted |
|---|---|---|---|---|
| Encryption at rest | , | Required | Required | Required + FIPS |
| Encryption in transit | , | Required | Required | Required (TLS 1.2+) |
| Access controls | , | Authn | RBAC least-priv | RBAC + MFA + tamper-evident audit |
| External sharing allowed | Yes | With care | NDA required | Written approval + encrypted channel |
| Generative-AI processing | Yes | Yes | Approved SaaS only | Prohibited unless SaaS is explicitly listed for Restricted |
| Backup required | Best-effort | Yes | Yes | Yes + cross-region + Object Lock |
| Retention default | As needed | 3 years | 7 years | Per legal / contractual minimum |
| Deletion method | Soft | Soft | Soft + crypto-erase backups | Crypto-erase + audit log |
4. Policy statements
- Every data store is labeled with a classification on creation. Unlabeled stores default to Confidential.
- Data inherits the highest classification of its source. Derived data from Restricted source is Restricted.
- Personnel handling Restricted data complete annual targeted training (HIPAA, PCI, CUI awareness, whichever applies).
- Printing of Confidential or Restricted data is prohibited unless explicitly authorized and the printed copy is logged and destroyed.
- No Rex Black or client data above Public may be copied to personal devices or personal accounts. Work-BYOD devices that are MDM-enrolled and disk-encrypted are permitted.
5. Client data
- Every client engagement is scoped to a classification in the SOW
and reflected on the client's
ClientOrgrecord. - Client data is tenant-isolated by
orgIdin all data stores. No cross-tenant query is permitted outside of approved, time-boxed engineering maintenance with an audit-logged elevation.
6. Roles & responsibilities
| Role | Responsibility |
|---|---|
| Privacy Officer | Owns the classification scheme; resolves disputes. |
| Data owner | Classifies data at creation; re-classifies on change. |
| All personnel | Handle data according to its classification. |
7. Enforcement & exceptions
Mis-classification or mis-handling of Restricted data is a security incident. Exceptions require Privacy Officer approval.
8. References
010-data-retention-and-disposal-policy.md011-encryption-standard.md026-ai-acceptable-use-policy.md028-data-subject-rights-policy.md
9. Revision history
| Version | Date | Author | Approver | Change |
|---|---|---|---|---|
| 1.0 | 2026-04-17 | P.O. | CEO | Initial policy |
Approval
This policy has been reviewed and is hereby approved for the named version and effective date above.
| Approved by | Myles Bai |
| Title | Chief Executive Officer, Rex Black LLC |
| myles@rexblack.com | |
| Approval date | 2026-04-17 |
| Effective date | 2026-04-17 |
| Next review due | 2027-04-17 |
Digital signature of record: the CEO's electronic approval is captured
in the platform audit log (event kind admin.policy.approved) with
hash-chained integrity under the M-C1 control. The hash-chained audit
log entry for this document is the canonical signature of record; this
printed block exists for print/review convenience.