Aramco data is not yours to classify however you see fit. SACS-002 requires that every vendor handling Aramco information maintains a formal Data Classification Policy that defines how data is categorized, stored, transmitted, and eventually destroyed. Without this policy, your team has no rules governing which data can be shared, where it can be stored, or who can access it -- and auditors will flag this gap immediately. This guide explains exactly what your Data Classification Policy must contain, how Aramco's own classification levels interact with your policy, and the common failures that cost vendors their CCC certification.

What the SACS-002 Standard Requires

Multiple TPC controls feed into data classification requirements. While there is no single "data classification" TPC number, the requirement emerges from the intersection of several controls:

Key controls: TPC-1 (Acceptable Use Policy must reference data handling), TPC-19 (media sanitization before disposal), TPC-52 (encryption of data in transit), and the overarching SACS-002 requirement that vendors protect Aramco information according to its classification level.

Auditors expect to see a standalone Data Classification Policy or a clearly defined section within your Information Security Policy that addresses classification levels, handling rules, and Aramco-specific data restrictions.

Aramco's Data Classification Levels

Aramco classifies its own information into distinct levels, and as a vendor, you must understand and respect these classifications. Your policy must define how each level is handled within your organization:

Classification Level Description Handling Requirements
Restricted Highly sensitive information whose disclosure could cause severe damage to Aramco Encrypted at rest and in transit, access limited to named individuals, no copies without authorization, secure destruction required
Confidential Sensitive business information not intended for public disclosure Encrypted in transit (TPC-52), access controlled by role, stored on authorized systems only, no sharing via personal channels
Internal Information intended for use within the vendor-Aramco relationship Access limited to employees with business need, stored on company systems, not to be shared externally without approval
Public Information approved for public disclosure No special handling requirements, but verify classification before treating data as public

The critical principle: when you receive data from Aramco, it retains Aramco's classification. You cannot reclassify it to a lower level. If Aramco marks a document as Confidential, it remains Confidential in your systems regardless of your own internal classification scheme.

Required Policy Sections

A compliant Data Classification Policy must include the following sections. Auditors will check for each one and verify that handling rules are specific enough to be actionable.

1. Purpose and Scope

Define the policy's objective (protecting information assets according to their sensitivity) and scope (all data created, received, stored, or transmitted in connection with Aramco work, across all systems, devices, and media).

2. Classification Levels and Definitions

Define your organization's classification levels and map them to Aramco's levels. Your internal scheme can use different names, but you must document the mapping. For example:

If your organization does not have its own classification scheme, adopt Aramco's levels directly. This is simpler and avoids mapping confusion during the audit.

3. Data Handling Rules by Classification

For each classification level, define specific rules covering:

Storage

Transmission

Access Control

Sharing and Disclosure

Retention and Destruction

4. Data Labeling Requirements

Define how data is labeled with its classification: document headers/footers, email subject line tags, file naming conventions, or metadata tags. Auditors may ask to see examples of properly labeled documents.

5. Aramco-Specific Disclosure Prohibitions

SACS-002 explicitly prohibits vendors from disclosing Aramco data to unauthorized parties. Your policy must include a clear section stating:

6. Roles and Responsibilities

Assign data classification responsibilities: who classifies data (the data owner or originator), who enforces handling rules (IT/security team), who audits compliance (internal audit or compliance officer), and who employees contact with classification questions.

7. Policy Review and Updates

The Data Classification Policy must be reviewed at least annually, or whenever Aramco updates its own classification requirements. Document the review schedule, approval process, and change history.

Common Audit Failures

  1. No classification policy exists: The vendor has never documented how data is classified or handled. This is a fundamental governance gap that affects multiple TPC controls.
  2. Generic policy without Aramco specifics: The vendor has an IT security policy that mentions "confidential data" but does not address Aramco's classification levels, disclosure prohibitions, or data return/destruction requirements.
  3. Policy exists but employees do not follow it: The auditor finds Aramco data stored on personal Google Drive accounts, shared via WhatsApp, or saved on unencrypted USB drives -- all violations of a policy that theoretically prohibits these actions.
  4. No data labeling: Documents containing Aramco data have no classification labels. Employees cannot tell whether a document is Confidential or Internal just by looking at it.
  5. Missing destruction procedures: The vendor has no documented process for destroying Aramco data when it is no longer needed. Old project files containing Aramco data sit on servers indefinitely with no review or cleanup.
  6. No mapping to Aramco levels: The vendor has its own classification scheme but has never mapped it to Aramco's levels. The auditor cannot determine whether "Level 2" in the vendor's system equates to Aramco's "Confidential" or "Internal."

Data Classification Audit Evidence Checklist

Evidence Item What to Prepare
Policy document Current version with classification levels, handling rules, Aramco-specific sections, version number, and review date
Classification mapping Table mapping your internal levels to Aramco's classification levels
Labeled document samples Examples of properly classified and labeled documents (redacted if necessary)
Storage configuration Evidence that Aramco data is stored on authorized, encrypted systems only
Encryption evidence TLS configuration for data in transit, encryption-at-rest configuration for storage systems
Destruction records Certificates of destruction or sanitization logs for any Aramco data that was disposed of
Employee acknowledgment Evidence that employees acknowledged the data handling rules (typically covered by AUP acknowledgment per TPC-1)
Annual review record Evidence that the policy was reviewed and approved within the last 12 months

How MassiveGRID's Template Accelerates Compliance

Writing a Data Classification Policy that addresses Aramco-specific requirements -- classification level mapping, disclosure prohibitions, data return obligations, destruction procedures -- requires understanding both the SACS-002 standard and Aramco's contractual expectations. Most vendors either overlook critical sections or write policies that are too generic to satisfy auditors.

MassiveGRID's CCC-Compliant Infrastructure Package includes a ready-made Data Classification Policy template that:

The encrypted file hosting and secure remote desktop components of the infrastructure package provide the technical controls that enforce the policy -- data is automatically stored on encrypted systems, transmitted over encrypted channels, and access-controlled via MFA, matching the handling rules in the template.

Get the Data Classification Template as Part of the Full CCC Package

The Data Classification Policy template is one of six governance templates included in the MassiveGRID Aramco CCC-Compliant Infrastructure Package, alongside the Acceptable Use Policy, Incident Response Plan, Risk Assessment Template, Off-boarding Checklist, and Media Sanitization Procedure. Combined with 10 infrastructure components and direct access to authorized audit firm partners, it provides the full path from zero to certified.

Explore the full CCC-compliant infrastructure package →