1. Purpose
The Confidentiality Requirements Matrix defines the minimum confidentiality and information-protection requirements that apply to information based on its classification, sensitivity, business purpose, and method of use or sharing.
The matrix helps ensure that employees, contractors, suppliers, customers, partners, and other authorized parties understand how information must be accessed, stored, transferred, disclosed, retained, and securely disposed of.
Core Principle
Classify → Determine Requirements → Authorize Access → Protect → Share Securely → Monitor → Retain/Delete → Verify
2. Scope
This matrix applies to information handled by:
- Employees
- Contractors
- Consultants
- Interns
- Temporary workers
- Suppliers
- Service providers
- Partners
- Customers
- Auditors
- Advisors
- Other authorized third parties
It applies to information stored or processed in:
- Laptops and desktops
- Mobile devices
- Cloud platforms
- SaaS applications
- Databases
- Source-code repositories
- File-sharing platforms
- Paper documents
- Removable media
- APIs
- Production environments
- Backup systems
- Collaboration platforms
3. Information Classification Levels
The organization may use the following classification levels.
| Classification | General Description | Typical Impact if Disclosed |
|---|---|---|
| Public | Information approved for public disclosure | Low |
| Internal | Information intended for internal business use | Low/Medium |
| Confidential | Sensitive business, customer, technical, or operational information | Medium/High |
| Restricted | Highly sensitive information requiring enhanced protection | High/Critical |
The organization’s approved Information Classification Policy should be the authoritative source for classification definitions.
4. Master Confidentiality Requirements Matrix
| Requirement | Public | Internal | Confidential | Restricted |
|---|---|---|---|---|
| Authorized access required | No | Yes | Yes | Yes |
| Need-to-know principle | Recommended | Yes | Yes | Strict |
| Named-user access | Recommended | Yes | Yes | Mandatory where practical |
| Shared accounts | Generally acceptable only where appropriate | Avoid | Prohibited unless specifically approved | Prohibited except controlled emergency use |
| MFA | Where applicable | Where applicable | Required for sensitive systems | Mandatory where technically applicable |
| Encryption in transit | Recommended | Recommended | Required for sensitive transfers | Required |
| Encryption at rest | Not normally required | Based on risk | Required where appropriate | Required |
| Secure file transfer | Not normally required | Recommended | Required | Required |
| External sharing | Publicly permitted | Authorized recipients | Explicit authorization | Explicit approval |
| Third-party disclosure | Permitted | Controlled | Contractual/authorized | Formal approval and contractual controls |
| Personal device storage | Generally permitted | Restricted | Only if approved and protected | Normally prohibited |
| Public cloud storage | Permitted where intended | Approved services | Approved services only | Approved and specifically controlled |
| Public AI tools | Permitted for public information | Only where approved | Prohibited unless explicitly approved | Prohibited unless formally approved |
| Source-code repositories | Public repositories where intentionally released | Private repositories | Approved private repositories | Highly restricted repositories |
| Email sharing | Permitted | Internal/approved recipients | Secure transmission required | Avoid where possible; approved secure channel |
| Printing | Permitted | Controlled | Restricted | Strictly controlled |
| Physical storage | No special requirement | Controlled | Secure storage | Locked/controlled storage |
| Logging | Normally not required | Risk-based | Required for sensitive access where appropriate | Required |
| Monitoring | Normally not required | Risk-based | Required where appropriate | Enhanced monitoring |
| Data retention | Business need | Defined | Defined | Strictly defined |
| Secure disposal | Normal disposal | Controlled disposal | Secure disposal | Secure destruction/deletion |
| Incident reporting | Required | Required | Immediate/priority reporting | Immediate/priority reporting |
| NDA/confidentiality agreement | Not normally required | Where appropriate | Normally required for external parties | Required |
| Access review | Not normally required | Periodic | Periodic | Frequent/risk-based |
| Data loss prevention | Not normally required | Risk-based | Recommended/required where appropriate | Required where appropriate |
| Regulatory restrictions | Usually low | May apply | May apply | Frequently applicable |
5. Public Information Requirements
Definition
Information intentionally approved for public disclosure.
Examples:
- Public website content
- Published marketing material
- Public documentation
- Published job advertisements
- Public press releases
- Public product information
Minimum Requirements
☐ Information approved for public release
☐ No confidential information included
☐ No personal information unnecessarily exposed
☐ No credentials or security secrets included
☐ No internal architecture unnecessarily disclosed
☐ No restricted customer information included
Disclosure
Public information may be shared externally without additional confidentiality approval where it has been formally approved for public release.
6. Internal Information Requirements
Definition
Information intended primarily for authorized personnel within the organization.
Examples:
- Internal procedures
- Internal meeting notes
- Internal operational information
- Non-public employee communications
- Internal project documentation
- Internal process information
Requirements
☐ Authorized personnel access
☐ Appropriate authentication
☐ Approved storage locations
☐ Controlled external sharing
☐ Secure disposal
☐ No unnecessary public disclosure
External Disclosure
External disclosure should require appropriate authorization.
7. Confidential Information Requirements
Definition
Information that could cause meaningful business, security, privacy, financial, contractual, or reputational impact if improperly disclosed.
Examples:
- Customer information
- Supplier information
- Business plans
- Contracts
- Pricing
- Security assessments
- VAPT reports
- Product roadmaps
- Technical architecture
- Non-public source code
- Internal audit reports
Requirements
☐ Need-to-know access
☐ Named user access where practical
☐ Strong authentication
☐ MFA for relevant systems
☐ Approved storage
☐ Encryption during sensitive transmission
☐ Encryption at rest where appropriate
☐ Controlled external sharing
☐ NDA/confidentiality requirements where applicable
☐ Secure disposal
☐ Security incident reporting
☐ Periodic access review
8. Restricted Information Requirements
Definition
Information where unauthorized access or disclosure could create significant or critical impact.
Examples:
- Production credentials
- Privileged credentials
- Encryption keys
- API secrets
- Highly sensitive customer data
- Sensitive personal data
- Unreleased security vulnerabilities
- Critical security architecture
- Major incident investigation evidence
- Highly sensitive intellectual property
Requirements
☐ Strict need-to-know access
☐ Individual named accounts
☐ MFA
☐ Privileged access controls
☐ Strong authentication
☐ Encryption
☐ Approved storage only
☐ Secure transfer
☐ Enhanced logging
☐ Access monitoring
☐ Periodic access review
☐ Formal authorization for external disclosure
☐ Secure deletion
☐ Incident escalation
☐ Evidence preservation where required
9. Access Control Matrix
| Access Requirement | Public | Internal | Confidential | Restricted |
|---|---|---|---|---|
| General access | Open | Authorized users | Need-to-know | Strict need-to-know |
| Manager approval | Not normally required | Where appropriate | Required where applicable | Required |
| System owner approval | No | Where appropriate | Recommended | Required |
| Privileged access | Not applicable | Limited | Restricted | Highly restricted |
| Temporary access | Not normally required | Recommended where appropriate | Preferred | Required where practical |
| Access expiry | No | Risk-based | Required for temporary access | Required |
| Periodic review | No | Periodic | Periodic | Frequent/risk-based |
| Emergency access | Not applicable | Controlled | Controlled | Strictly controlled and logged |
10. Storage Requirements Matrix
| Storage Location | Public | Internal | Confidential | Restricted |
|---|---|---|---|---|
| Public website | Allowed | Prohibited unless approved | Prohibited | Prohibited |
| Corporate file storage | Allowed | Allowed | Approved location | Approved restricted location |
| Approved SaaS | Allowed | Allowed | Approved services | Explicitly approved services |
| Personal cloud storage | Generally unnecessary | Restricted | Prohibited unless approved | Prohibited |
| Local workstation | Allowed | Allowed | Protected | Restricted |
| Removable media | Allowed | Controlled | Restricted | Normally prohibited |
| Source-code repository | Public if intentionally public | Private | Private restricted | Highly restricted |
| Backup | As applicable | Required where appropriate | Protected | Strongly protected |
11. Information Transfer Matrix
| Transfer Method | Public | Internal | Confidential | Restricted |
|---|---|---|---|---|
| Public website | Yes | No | No | No |
| Normal email | Yes | Controlled | Avoid unless protected | Avoid |
| Encrypted email | Yes | Yes | Yes | Where approved |
| Approved file sharing | Yes | Yes | Yes | Yes, if authorized |
| Secure API | Yes | Yes | Yes | Yes |
| Public file-sharing link | Yes | No | No | No |
| Encrypted transfer | Optional | Recommended | Required | Required |
| Physical delivery | Optional | Controlled | Secure delivery | Secure tracked delivery |
12. Third-Party Disclosure Matrix
| Requirement | Public | Internal | Confidential | Restricted |
|---|---|---|---|---|
| External disclosure | Allowed if approved for public release | Authorization required | Formal authorization | Formal approval |
| NDA | Usually unnecessary | Where appropriate | Normally required | Required |
| Security review | No | Risk-based | Recommended | Required where appropriate |
| Supplier assessment | No | Risk-based | Required for relevant suppliers | Required |
| Data-processing agreement | No | If personal data applies | If personal data applies | Required where applicable |
| Subprocessor review | No | Where applicable | Required where applicable | Required |
| Disclosure logging | Not normally required | Risk-based | Recommended | Required where appropriate |
13. Customer Information Requirements
Where customer information is classified as Confidential or Restricted:
☐ Customer requirements identified
☐ Contractual confidentiality requirements reviewed
☐ Customer data minimized
☐ Access restricted
☐ Approved storage used
☐ Secure transfer used
☐ Encryption considered/implemented
☐ Retention defined
☐ Deletion/return requirements defined
☐ Incident notification requirements understood
☐ Subprocessor requirements considered
14. Personal Data Requirements
Where personal data is involved:
☐ Processing purpose identified
☐ Data minimization applied
☐ Access restricted
☐ Appropriate security controls implemented
☐ Retention defined
☐ Secure deletion defined
☐ External disclosure controlled
☐ Applicable privacy requirements identified
☐ International transfer requirements assessed where applicable
☐ Data-processing agreement completed where required
15. Security Credentials and Secrets
The following should normally be treated as Restricted:
- Passwords
- API keys
- Access tokens
- SSH private keys
- Cloud credentials
- Encryption keys
- Database credentials
- Signing keys
- Certificates containing private keys
- Break-glass credentials
Requirements
☐ Named access where possible
☐ MFA
☐ Secure secrets storage
☐ No storage in source code
☐ No sharing through unsecured channels
☐ Rotation
☐ Revocation
☐ Access logging
☐ Compromise response
16. Source Code Requirements
Non-public source code should normally be classified as Confidential or Restricted, depending on business impact.
Requirements
☐ Private repository
☐ Named users
☐ Need-to-know access
☐ MFA
☐ Branch/repository protection
☐ Access review
☐ No unauthorized copying
☐ No upload to public repositories
☐ No submission to unapproved AI services
☐ Secure backup
☐ Access revocation during offboarding
17. Security Vulnerability Information
Information relating to vulnerabilities should receive enhanced protection.
Examples:
- VAPT findings
- Exploit details
- Security weaknesses
- Unpatched vulnerabilities
- Penetration-test reports
- Security incident investigation details
Requirements
☐ Restricted access
☐ Need-to-know
☐ Secure storage
☐ Secure transfer
☐ Controlled external disclosure
☐ Appropriate remediation tracking
☐ No public disclosure before authorization
18. AI and Generative AI Requirements
Before entering information into an AI or external processing service, determine:
| Question | Requirement |
|---|---|
| Is the information Public? | Generally permitted subject to policy |
| Is it Internal? | Use only approved services |
| Is it Confidential? | Explicit approval may be required |
| Is it Restricted? | Normally prohibited unless specifically authorized |
| Is personal data involved? | Privacy/legal assessment required |
| Is customer data involved? | Customer/contractual requirements must be considered |
| Is source code involved? | Approved AI service required |
| Is security information involved? | Enhanced approval required |
Prohibited Practice
Do not paste passwords, API keys, customer data, private source code, or sensitive security findings into an unapproved public AI service.
19. Remote Work Requirements
For Confidential and Restricted information:
☐ Authorized devices only
☐ Strong authentication
☐ MFA where applicable
☐ Device encryption
☐ Secure network access
☐ Screen/privacy protection
☐ No unauthorized family/shared access
☐ Approved cloud storage
☐ Secure physical handling
☐ Secure disposal
20. Printing Requirements
| Classification | Printing Requirement |
|---|---|
| Public | No special restriction |
| Internal | Controlled where appropriate |
| Confidential | Minimize printing; secure storage |
| Restricted | Printing only when necessary and authorized |
Printed Confidential or Restricted information should not be left unattended.
21. Retention and Disposal Matrix
| Requirement | Public | Internal | Confidential | Restricted |
|---|---|---|---|---|
| Retention based on business need | Recommended | Yes | Yes | Strictly defined |
| Retention schedule | Optional | Recommended | Required where applicable | Required |
| Normal disposal | Yes | Controlled | Secure disposal | Secure destruction/deletion |
| Data deletion verification | No | Risk-based | Where required | Where appropriate |
| Legal hold consideration | Yes | Yes | Yes | Yes |
22. Security Incident Requirements
Any suspected unauthorized disclosure should be reported through the organization’s incident-management process.
Examples
- Wrong recipient received an email;
- Confidential document sent to an unauthorized person;
- Laptop containing Restricted information was lost;
- Customer data was uploaded to an unapproved service;
- Source code was exposed publicly;
- Credentials were accidentally disclosed;
- Confidential information was shared with an unauthorized supplier.
Required Actions
Report → Contain → Assess → Preserve Evidence → Notify → Remediate → Record → Review
23. Third-Party Confidentiality Requirements
Before providing Confidential or Restricted information to an external party:
☐ Business need identified
☐ Third party identified
☐ Information classified
☐ Access scope defined
☐ NDA/confidentiality agreement reviewed
☐ Security requirements defined
☐ Personal-data requirements assessed
☐ Supplier risk assessed where applicable
☐ Secure transfer method defined
☐ Retention/deletion requirements defined
☐ Incident notification requirements defined
24. Contractual Requirements
Contracts involving Confidential or Restricted information should address relevant requirements such as:
- Confidentiality
- Information security
- Access control
- Data protection
- Incident notification
- Subprocessors
- Data location
- Data retention
- Data deletion
- Return of information
- Security assurance
- Audit rights where appropriate
- Business continuity
- Termination
- Exit requirements
25. Evidence Requirements
The organization should retain appropriate evidence demonstrating that confidentiality requirements are implemented.
Examples:
☐ Classification records
☐ Access approvals
☐ Access review records
☐ NDA records
☐ Supplier agreements
☐ Data-processing agreements
☐ Secure transfer records
☐ Security assessment records
☐ Incident records
☐ Deletion confirmations
☐ Offboarding records
☐ Security training records
☐ Policy acknowledgements
☐ Exception approvals
Evidence should not unnecessarily contain passwords, API keys, private keys, or other secrets.
26. Responsibility Matrix
| Activity | Information Owner | IT/Security | Employee/User | Supplier |
|---|---|---|---|---|
| Classification | A/R | C | C | C |
| Access approval | A/R | C | I | C |
| Access provisioning | I | A/R | I | C |
| Secure handling | A | C | R | R |
| Secure transfer | A | C/R | R | R |
| External disclosure | A/R | C | I | C |
| Incident reporting | A | R | R | R |
| Retention | A/R | C | I | C |
| Secure disposal | A | R | R | R |
| Periodic review | A/R | R | C | C |
R = Responsible
A = Accountable
C = Consulted
I = Informed
27. Exception Management
Where the standard confidentiality requirements cannot be implemented:
- Document the exception.
- Identify the reason.
- Assess the risk.
- Define compensating controls.
- Obtain appropriate approval.
- Define an expiry/review date.
- Record the exception.
Exception Record
| Field | Details |
|---|---|
| Exception ID | |
| Information | |
| Classification | |
| Requirement | |
| Reason | |
| Risk | |
| Compensating Control | |
| Owner | |
| Approver | |
| Expiry/Review Date | |
| Status |
28. AWS SaaS Startup Example
An AWS SaaS startup classifies the following information:
| Information | Classification | Key Requirements |
|---|---|---|
| Public website content | Public | Approved for public release |
| Internal sprint plan | Internal | Authorized internal access |
| Customer contract | Confidential | Need-to-know, secure storage |
| VAPT report | Restricted | Strict access, secure transfer |
| AWS architecture | Confidential | Restricted access, approved sharing |
| Production database credentials | Restricted | Secrets manager, MFA, logging |
| API key | Restricted | Secure storage, rotation |
| Public API documentation | Public | Approved publication |
| Customer personal data | Confidential/Restricted | Privacy + access controls |
| Source code | Confidential/Restricted | Private repository, MFA |
| Security incident evidence | Restricted | Strict access, evidence preservation |
Practical Example
A developer needs to share an AWS architecture diagram with a VAPT provider.
The process should be:
Classify → Verify Provider → NDA → Approve Access → Secure Transfer → Limit Access → Review → Revoke/Return
The diagram should not simply be attached to an unrestricted email or uploaded to a public file-sharing service.
29. Startup-Friendly Implementation Model
A startup does not need a complicated confidentiality framework.
Start with four clear rules:
Rule 1 — Classify
Every important information asset should have a classification.
Rule 2 — Restrict
Confidential and Restricted information should only be accessible to people who need it.
Rule 3 — Protect
Use appropriate authentication, encryption, secure storage, and secure transfer.
Rule 4 — Close
When access or business need ends, remove access and return/delete information as required.
Startup Minimum Controls
☐ Information classification policy
☐ Confidentiality/NDA requirements
☐ Access control
☐ MFA
☐ Approved cloud storage
☐ Secure file sharing
☐ Secure secrets management
☐ Employee/contractor offboarding
☐ Supplier confidentiality requirements
☐ Incident reporting
☐ Secure disposal
30. Common Mistakes
Avoid:
- Treating all information as equally sensitive.
- Marking everything “Confidential” without defining handling requirements.
- Granting access based on convenience.
- Sharing customer data when test data would be sufficient.
- Sending Restricted information through normal email.
- Storing credentials in documents or source code.
- Uploading confidential information to public AI tools.
- Allowing suppliers unrestricted access.
- Forgetting to revoke access after a project ends.
- Keeping confidential information indefinitely.
- Failing to document exceptions.
- Assuming an NDA alone protects information.
- Keeping audit evidence that contains actual passwords or secrets.
31. Relationship With Other ISMS Documents
| Document | Relationship |
|---|---|
| Information Classification Policy | Defines classification principles |
| Information Classification Register | Records classified information |
| Confidentiality and NDA Policy | Defines confidentiality obligations |
| Employee NDA | Protects employee-handled information |
| Contractor NDA | Protects contractor-handled information |
| Supplier Confidentiality Agreement | Protects supplier-shared information |
| Access Management Procedure | Controls access |
| Information Transfer Procedure | Controls information exchange |
| Data Retention Policy | Defines retention requirements |
| Secure Disposal Procedure | Defines secure destruction |
| Incident Response Procedure | Handles unauthorized disclosure |
| Supplier Security Requirements | Defines third-party protection |
| Employee Offboarding Policy | Supports access and information protection at exit |
| Data Processing Agreement | Addresses personal-data processing |
32. ISO 27001 / SOC 2 Connection
The Confidentiality Requirements Matrix supports the organization’s broader information-security framework by translating information classification into practical protection requirements.
It can provide evidence that the organization has considered:
- Information classification;
- Access control;
- Need-to-know;
- Information transfer;
- Confidentiality obligations;
- Supplier/third-party protection;
- Secure disposal;
- Incident management;
- Data protection;
- Security monitoring.
The matrix itself is not a substitute for the organization’s risk assessment, policies, procedures, or applicable ISO 27001/SOC 2 controls.
The organization should determine the controls and requirements appropriate to its specific risks, services, information, contractual obligations, and regulatory environment.
33. Quick Audit Checklist
☐ Information classification defined
☐ Classification levels approved
☐ Confidentiality requirements documented
☐ Access requirements defined
☐ Need-to-know implemented
☐ MFA requirements defined
☐ Encryption requirements defined
☐ Secure transfer requirements defined
☐ Third-party disclosure requirements defined
☐ NDA requirements defined
☐ Customer data requirements defined
☐ Personal-data requirements defined
☐ AI/external-service requirements defined
☐ Source-code requirements defined
☐ Credential/secret requirements defined
☐ Retention requirements defined
☐ Secure disposal requirements defined
☐ Incident reporting defined
☐ Exception process defined
☐ Evidence requirements defined
☐ Periodic review established
34. Document Control
| Field | Details |
|---|---|
| Document Name | Confidentiality Requirements Matrix |
| Document Owner | |
| Version | |
| Effective Date | |
| Review Frequency | |
| Approved By | |
| Classification | Internal |
| Next Review Date | |
| Status | Draft / Approved / Retired |
35. Final Audit Trail
For every significant category of information, the organization should be able to demonstrate:
What information is it?
How is it classified?
Who owns it?
Who can access it?
Why do they need access?
Where can it be stored?
How can it be transferred?
Can it be shared with third parties?
What contractual requirements apply?
Can it be processed using AI or external services?
How long should it be retained?
How should it be deleted or destroyed?
What happens if it is disclosed accidentally?
What evidence demonstrates that the requirements were followed?
Final Principle
Classification has value only when it changes how information is handled. The Confidentiality Requirements Matrix converts labels such as Public, Internal, Confidential, and Restricted into clear, measurable security requirements that users and third parties can actually follow.
