The first step when creating a data classification program is to develop a policy (D). A data classification policy is a document that defines the purpose, scope, objectives, roles, responsibilities, and procedures of the data classification program. A data classification policy is essential for establishing the governance framework, standards, and guidelines for the data classification process. A data classification policy also helps to communicate the expectations and benefits of the data classification program to the stakeholders, such as data owners, users, custodians, and auditors12.

Categorizing and prioritizing data (A) is not the first step when creating a data classification program, but the third step. Categorizing and prioritizing data involves defining and applying the criteria and labels for classifying data based on its sensitivity, value, and risk. For example, data can be categorized into public, internal, confidential, or restricted levels. Categorizing and prioritizing data helps to identify and protect the most critical and sensitive data assets of the organization12.

Developing data process maps (B) is not the first step when creating a data classification program, but the fourth step. Developing data process maps involves documenting and analyzing the flow and lifecycle of data within the organization. Data process maps show how data is created, collected, stored, processed, transmitted, used, shared, archived, and disposed of. Developing data process maps helps to understand the context and dependencies of data, as well as to identify and mitigate any potential risks or issues related to data quality, security, or compliance12.

Categorizing information by owner © is not the first step when creating a data classification program, but the second step. Categorizing information by owner involves assigning roles and responsibilities for each type of data based on its ownership and stewardship. Data owners are the individuals or entities that have the authority and accountability for the data. Data stewards are the individuals or entities that have the operational responsibility for managing and maintaining the data. Data custodians are the individuals or entities that have the technical responsibility for implementing and enforcing the security and access controls for the data12.