Pillar 4: Data

Data is the asset Zero Trust ultimately protects. This pillar focuses on transparency and visibility enabled by enterprise infrastructure, applications, standards, robust end-to-end encryption, and data tagging/classification.

Key principles

  • Data is classified and labeled before access policy can be applied to it.
  • Encryption is applied by default, not as an exception.
  • Access to data is governed by policy tied to sensitivity, not just to the system that stores it.

Maturity snapshot

Stage Characteristics
Traditional Manual, inconsistent classification; encryption applied ad hoc
Advanced Automated DLP/CASB-driven classification; policy-enforced encryption across most stores
Optimal Continuous ML-assisted classification driving real-time access policy; end-to-end encryption with centralized key management

See Data Classification & Labeling and Encryption at Rest & In Transit in the capability matrix.

Framework tie-ins

NIST 800-53 (RA, SC families), GLBA Safeguards Rule (16 CFR 314.4(c)), PCI-DSS v4.0 (Req. 3, 4), NYDFS 500 (500.03, 500.15).

Capabilities in this pillar

Data Classification & Labeling

Traditional

Manual, inconsistent classification

Advanced

Automated classification via DLP/CASB tooling

Optimal

Continuous, ML-assisted classification enforcing access policy in real time

NIST 800-53 (RA-2)GLBA (Safeguards Rule) (16 CFR 314.4(c))NYDFS 500 (500.03)

Encryption at Rest & In Transit

Traditional

Encryption applied inconsistently, mostly in transit only

Advanced

Encryption enforced by policy across most data stores and channels

Optimal

End-to-end encryption with centralized key management and rotation

PCI-DSS v4.0 (3.5 / 4.2)NYDFS 500 (500.15)

Key Management / HSM

Traditional

Software-based key storage; manual rotation

Advanced

Centralized KMS/HSM with policy-based rotation

Optimal

Hardware-backed, automated key lifecycle management with real-time revocation

PCI-DSS v4.0 (3.6)NYDFS 500 (500.15)

Data Residency & Sovereignty Controls

Traditional

No enforcement of data location

Advanced

Policy-based data residency enforcement for regulated data

Optimal

Automated, continuously verified data residency compliance across all storage and processing locations

GLBA (Safeguards Rule) (16 CFR 314.4(c))NYDFS 500 (500.03)

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