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07 — Data Classification & Handling Policy

Owner Security + Legal
Review cadence Annual
Approver CTO
Last reviewed 2026-04
Mapped controls C1.1, C1.2, P3.1, P4.1

1. Classification levels

Level Definition Examples Handling
Public Intended for free distribution Marketing site, public docs, ANATEL/OpenCelliD/SRTM tower data No restrictions
Internal Routine business info; not for external distribution Internal runbooks, SLO targets, postmortem drafts Workforce only; standard tooling
Confidential Customer data; business sensitive Customer email, API keys (hashed), audit log entries, billing records, Stripe customer IDs Encrypted at rest + in transit; access only on need-to-know; audit-logged
Restricted Highly sensitive; regulatory or contractual Cognito JWT signing keys, AWS KMS keys, Stripe webhook secret, PagerDuty routing key, employee PII Stored in AWS SSM SecureString or KMS; access requires MFA + ticket; access logged via CloudTrail

2. Labelling

  • DB tables containing Confidential/Restricted data are documented in models.py with a # CLASS: confidential or # CLASS: restricted comment on the class.
  • S3 buckets are labelled via tag data-classification: <level>.
  • Files in evidence/ follow the same tagging.

3. Encryption

  • At rest: All Confidential and Restricted data encrypted via AWS KMS (RDS, EBS, S3, SSM SecureString).
  • In transit: TLS 1.2+ enforced. See 08-encryption.md for cipher suite and key-management detail.

4. Retention

Class Default retention
Public Indefinite
Internal 5 years (then archive or delete per relevance)
Confidential — billing & audit 5 years (LGPD/IRS-equivalent)
Confidential — customer payload Term of contract + 30 days
Restricted — secrets Until rotation; old versions deleted within 90 days

5. Disposal

  • Customer payload data deleted (cryptographic erasure or DB purge) within 30 days of contract termination, with a deletion certificate available on request.
  • Backups age out per S3 lifecycle (Glacier Deep Archive then expire).
  • Workforce devices wiped with vendor-validated procedure on offboarding.

6. Customer obligations (CSOCs)

Customers acknowledge in their agreement that:

  • API keys are Restricted data and must be stored in a secrets manager.
  • They will not include third-party PII in name or notes fields beyond what's needed for the RF analysis.
  • They are responsible for LGPD/GDPR obligations toward their own end-users for any data they ingest.

7. PII inventory

  • Collected by TELECOM TOWER POWER: billing email, company name, billing address, tier, Stripe customer ID, IP address (audit log), Cognito user sub (for SSO users).
  • Not collected: national ID numbers, payment card data (handled exclusively by Stripe), biometric data, location data of end-users.
  • Inferred from inputs: geographic coordinates of receiver locations (treated as Confidential per data-min principle).