Classification of data starts with defining that data. Unfortunately there are many definitions for personal or private information and these definitions are often different depending on country, state, organization, regulation, and other factors.
Ferpa gives the following guidance:
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Schools may disclose, without consent, “directory” information such as a student’s name, address, telephone number, date and place of birth, honors and awards, and dates of attendance.
The State of Texas provides these definitions in the Texas Administrative Code 202:
Confidential Information–Information that is excepted from disclosure requirements under the provisions of applicable state or federal law, e.g. the Texas Public Information Act.
Mission Critical Information–Information that is confidential or is defined by the institution of higher education, or state agency to be essential to the institution of higher education, or state agency function(s).
estricted Personal Information–Includes an individual’s social security number, or data protected under state or federal law (e.g., financial, medical or student data).
All of these statements leave something to be desired when trying to provide specific guidance. As an information security manager for a university in Texas I have taken to referring to the Texas Statue “BUSINESS & COMMERCE CODE CHAPTER 48. UNAUTHORIZED USE OF IDENTIFYING INFORMATION SUBCHAPTER A. GENERAL PROVISIONS” which states:
(1) “Personal identifying information” means information that alone or in conjunction with other information identifies an individual, including an individual ’s:
- (A) name, social security number, date of birth, or government-issued identification number;
- (B) mother ’s maiden name;
- (C) unique biometric data, including the individual ’s fingerprint, voice print, and retina or iris image;
- (D) unique electronic identification number, address, or routing code; and
- (E) telecommunication access device.
(2) “Sensitive personal information”:
- (A) means an individual ’s first name or first initial and last name in combination with any one or more of the following items, if the name and the items are not encrypted:
- (i) social security number;
- (ii) driver ’s license number or government-issued identification number; or
- (iii) account number or credit or debit card number in combination with any required security code, access code, or password that would permit access to an individual ’s financial account; and
- (B) does not include publicly available information that is lawfully made available to the general public from the federal government or a state or local government.
Although this does leave some area for debate, it is more informative than other sources.
What sources do you use for explaining the types of information that need to be protected within your organization?
You can post your responses here or you can head over to the Security Catalyst Community to see what other information security professionals have to say about their sources. Just look for the post titled “How do you explain the definition of “Sensitive Information”?“.
Go forth and do good things,
Cutaway
SCC, Ferpa, Security Ripcord, sensitive information 







