The foundational step in any information classification program is to establish the framework upon which all other activities will be based. This involves specifying the criteria that define the classification levels (e.g., Public, Internal, Confidential, Restricted). These criteria determine how data is categorized based on its sensitivity, criticality, and impact if disclosed. All subsequent steps, such as assigning security controls, appointing custodians, and establishing review procedures, are dependent on this initial, fundamental definition. Without clear criteria, the classification process would be arbitrary, inconsistent, and ultimately ineffective.

A. Establishing review procedures is a governance and maintenance step that occurs after the initial classification program has been defined and implemented.

B. Specifying security controls for each level can only be done logically after the classification levels and their corresponding criteria have been established.

C. Identifying a data custodian is an operational step to assign responsibility, which follows the creation of the classification framework that the custodian will manage.

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1. Official (ISC)² Guide to the SSCP CBK

5th Edition. Chapter 2

"Security Operations and Administration

" in the section "Implement and Support Data-Labeling Policies

" explains that the creation of a data classification policy begins with defining the objectives and criteria for classification before assigning roles or controls.

2. NIST Special Publication 800-60 Vol. 1 Rev. 1

Guide for Mapping Types of Information and Information Systems to Security Categories. Section 2.1

"The Security Categorization Process

" outlines the initial step as identifying the types of information to be protected. This act of identification and understanding is integral to defining the criteria for how they will be classified based on impact.

3. University of California

Berkeley

Data Classification Standard. This official university document exemplifies the correct process. The standard begins by defining the "Protection Levels" (PLs) and "Availability Levels" (ALs)

which constitute the criteria for classification

before it proceeds to detail any roles

responsibilities

or specific controls. (See Section III

"UC Berkeley Data Classification

" and Section IV

"UC Berkeley Data Availability Classification").