3.7·high·Component: IdentifyWhat this control requires
Establish and maintain an overall data classification scheme for the enterprise. Enterprises may use labels, such as "Sensitive," "Confidential," and "Public," and classify their data according to those labels. Review and update the classification scheme annually, or when significant enterprise changes occur that could impact this Safeguard.
In plain English
Establish and maintain an overall data classification scheme for the enterprise. In practice, this means you can prove you establish and maintain data classification scheme-level controls on a defined cadence.
Why it matters
The CIS Controls are an industry-vetted, prioritised defence: skipping a safeguard widens the attack surface that the safeguards above and below it assume is closed. Audit frameworks (FedRAMP, PCI DSS, HIPAA) all cite CIS as evidence of due care.
This control is rated high. Auditors expect a named owner, a remediation SLA, and a tooling artefact that evidences continuous operation.
What an auditor looks for
A CIS-aligned reviewer wants to see (a) which Implementation Group you are targeting, (b) a documented owner for the safeguard, and (c) a tooling or process artefact (config, scan output, ticket) that proves the safeguard runs on the cadence the control demands.
Within Identify, the assessor will trace your implementation back to the catalogue reference (Control 3.7) and look for objective evidence on the latest two assessment cycles.
How to implement
Policy Management
Docs. Keep each policy in version-controlled Markdown alongside the code that implements it; ship a signed PDF snapshot at each annual review and link the SHA into the SoA.
Operational checklist
- Establish And Maintain. Document the trigger, the owner and the cadence.
- Classify. Document the trigger, the owner and the cadence.
- Scope: data classification scheme, sensitive, confidential, public, enterprise.
Evidence to collect
- Policy Document. A signed and version-controlled policy / standard / procedure document.
Signed policy or standard documents the safeguard. Focus: Establish and Maintain a Data Classification Scheme.
Common pitfalls
- Policies that no engineer has read; the version in Confluence drifts from the version that's actually being enforced.
Related controls in CIS Controls v8
- Control 3.2 — Establish and Maintain a Data Inventory
- Control 3.1 — Establish and Maintain a Data Management Process
- Control 3.8 — Document Data Flows
- Control 11.1 — Establish and Maintain a Data Recovery Process
- Control 12.4 — Establish and Maintain Architecture Diagram(s)
- Control 3.12 — Segment Data Processing and Storage Based on Sensitivity
References
- Center for Internet Security — CIS Controls v8
- Catalogue identifier:
Control 3.7
Topics: governance riskpatch managementpolicy management