Key Points
Why Data Classification Matters
- Data classification is mandatory at Pomona College
- Pomona uses three tiers: Public, Proprietary, Restricted
- Restricted data requires encryption (AES-256-GCM) using gocryptfs
- Data breaches have significant business, legal, and reputational costs
- PIs are responsible for classification; you implement it correctly
- Incident reporting is your responsibility; contact its-hpc@pomona.edu immediately if compromised
Regulations and Compliance
- Multiple regulations (FERPA, EAR/ITAR, NIST 800-171) drive Pomona’s data policy
- FERPA protects student education records; violations risk federal funding
- Export controls (EAR/ITAR) apply to cryptography, advanced materials, and dual-use research
- NIST SP 800-171 governs DOD-funded research with CUI
- Pomona’s Information Security Policy applies to all data on college systems
- When in doubt about export control, consult ORSP before sharing or publishing
The Three Tiers Overview
- Public data is either fully publicly available or freely shared within lab/groups; no special handling required
- File permissions: PUBLIC=755 (canonical)
- Public data still requires attribution and version control
- Two categories exist: fully public and shared internal to groups
- Classification determines where data is stored and how it’s protected
Identifying Data Types
- Proprietary data is restricted to specific authorized individuals; encryption recommended
- Restricted data requires mandatory encryption (AES-256-GCM via gocryptfs) and audit logging
- File permissions: PUBLIC=755, PROPRIETARY=750 (canonical; 600 variant for sub-team-only files), RESTRICTED=700+gocryptfs
- FERPA, EAR/ITAR, CUI, and PII data are automatically Restricted
- When in doubt, classify conservatively and ask your PI
The Classification Process
- Inventory your data: know what you have before classifying
- Understand content: ask whether your data contains PII, health info, export-controlled tech
- Apply rules systematically: check Regulatory triggers first, then Proprietary, then Public
- Classification is not a one-time event; re-classify as research evolves
- Ask for help: consult PI, ORSP, or ITS when uncertain
Decision Framework
- Use the decision tree to classify systematically: check regulatory triggers first
- Document decisions: create an audit trail for classification choices
- Re-classify regularly: as research evolves (publication, sharing, retention end)
- Avoid common mistakes: classifying by format, over-classifying, or never reclassifying
- Implement requirements: classification is meaningless without proper handling
Handling PUBLIC Data
- Public data: World-readable (755) or group-readable (750); no encryption needed
- Use
/bigdatafor large public datasets;/rhomeis acceptable for small files - No audit logging or special retention required for Public data
- Still verify data was approved for public release before sharing
Handling PROPRIETARY Data
- Proprietary data: Group-readable (750) or owner-only (600); optional encryption for sensitive assets
- Access control is enforced through file permissions, not trust
- External sharing requires collaboration agreement + secure transfer + time-limited access
- Retention varies by use case; reclassify to Public after publication
Handling RESTRICTED Data
- Restricted data: Owner-only (700) PLUS mandatory encryption (AES-256-GCM via gocryptfs); audit logging required
- Every access to Restricted data must be logged for compliance
- Create explicit access authorization lists; review annually
- Retention and secure deletion are required by regulation; use
shrednotrm - Never transfer Restricted data unencrypted; use SSH/SCP or institutional channels
Storage and Encryption
- Use
/rhomefor encrypted Restricted data (smaller, backed up);/bigdatafor large encrypted data - /rhome and /bigdata share 1 TB quota on BeeGFS
- gocryptfs provides AES-256-GCM encryption without root access
- Create encrypted container once, mount/unmount as needed
- Always unmount when not actively using Restricted data
- Back up the encrypted container, not the unencrypted contents
- Passphrase must be 14+ characters (NIST SP 800-63B); store securely, never share
Sharing and Collaboration
- Public data can be shared freely with anyone
- Proprietary data requires collaboration agreement + secure transfer
- Restricted data cannot be shared directly; must be de-identified first
- Use institutional Box/OneDrive; avoid personal cloud storage (Google Drive, Dropbox)
- Export-controlled research requires ORSP approval before international sharing
- Publish data with DOI for reproducibility and impact
De-identification and Best Practices
- De-identification removes identifiers while preserving research value
- Four techniques: removal, aggregation, generalization, perturbation
- Keep mapping files encrypted and separate from de-identified data
- Publish data with DOI for reproducibility and impact
- Data use agreements formalize access and protection obligations
- Proper data classification protects your research, your community, and Pomona College