= Information classification is the process of assigning appropriate labels to information assets based on their sensitivity and value to the organization. Information classification should be aligned with the business objectives and risk appetite of the organization, and should be reviewed periodically to ensure its accuracy and relevance. The information security manager is responsible for establishing and maintaining the information classification policy and procedures, as well as providing guidance and oversight to the data owners and custodians. Data owners are the individuals who have the authority and accountability for the information assets within their business unit or function. Data owners are responsible for determining the appropriate classification level and security controls for their information assets, as well as ensuring compliance with the information classification policy and procedures. Data custodians are the individuals who have the operational responsibility for implementing and maintaining the security controls for the information assets assigned to them by the data owners.

If the information security manager believes that information has been classified inappropriately, increasing the risk of a breach, the best action is to complete a risk assessment and refer the results to the data owners. A risk assessment is a systematic process of identifying, analyzing, and evaluating the risks associated with the information assets, and recommending appropriate risk treatment options. By conducting a risk assessment, the information security manager can provide objective and evidence-based information to the data owners, highlighting the potential impact and likelihood of a breach, as well as the cost and benefit of implementing additional security controls. This will enable the data owners to make informed decisions about the appropriate classification level and security controls for their information assets, and to justify and document any deviations from the information classification policy and procedures.

The other options are not the best actions for the information security manager. Refering the issue to internal audit for a recommendation is not the best action, because internal audit is an independent and objective assurance function that provides assurance on the effectiveness of governance, risk management, and control processes. Internal audit is not responsible for providing recommendations on information classification, which is a management responsibility. Re-classifying the data and increasing the security level to meet business risk is not the best action, because the information security manager does not have the authority or accountability for the information assets, and may not have the full understanding of the business context and objectives of the data owners. Instructing the relevant system owners to reclassify the data is not the best action, because system owners are not the same as data owners, and may not have the authority or accountability for the information assets either. System owners are the individuals who have the authority and accountability for the information systems that process, store, or transmit the information assets. System owners are responsible for ensuring that the information systems comply with the security requirements and controls defined by the data owners and the information security manager. References = CISM Review Manual, 16th Edition, ISACA, 2020, pp. 49-51, 63-64, 69-701; CISM Online Review Course, Domain 3: Information Security Program Development and Management, Module 2: Information Security Program Framework, ISACA2