1. Classification Overview
All data processed, stored, or transmitted within K0nsult CNC operations must be classified into one of seven categories. Classification determines handling requirements, access controls, storage jurisdiction, and retention periods.
| Category |
Examples |
Handling |
Storage |
Retention |
| Public |
Marketing materials, public documentation, blog posts |
Standard |
Any location |
Indefinite |
| Internal |
Agent configs, mission details, internal memos |
Encrypted in transit |
EU only |
24 months |
| Confidential |
Client briefs, proposals, strategic plans |
Encrypted at rest + in transit |
EU only |
Per contract |
| PII |
Names, emails, PESEL, phone numbers |
GDPR compliant, minimized |
EU only |
Per consent |
| Financial |
Invoices, payments, pricing models |
Encrypted, access-logged |
EU only |
5 years |
| Regulated |
Health data, legal records, banking data |
Per applicable regulation |
Client infrastructure |
Per regulation |
| Training |
Model inputs, feedback loops, evaluation data |
Anonymized before use |
EU only |
12 months |
2. Detailed Category Specifications
- Access
- All employees, agents, contractors, and the general public.
- Logging
- No mandatory logging. Optional analytics tracking permitted.
- Deletion Procedure
- Standard content removal. No special approval required.
- Breach Protocol
- Not applicable — data is public by definition. Monitor for unauthorized modification only.
- Access
- K0nsult team members, authorized agents, 0n40i4. No client access unless explicitly granted.
- Logging
- Access logged with timestamp and user identity. Logs retained 12 months.
- Deletion Procedure
- K02 approval required. Data wiped from all replicas within 30 days. Deletion certificate generated.
- Breach Protocol
- Internal incident review within 24 hours. No external notification unless data reclassified upward.
- Access
- Named individuals only. Access requires role justification and K02 approval. Time-limited access tokens.
- Logging
- Full audit trail: read, write, copy, export, delete. Logs immutable, retained for contract duration + 24 months.
- Deletion Procedure
- Dual approval (K02 + data owner). Cryptographic erasure. Third-party deletion confirmation for shared data.
- Breach Protocol
- Immediate containment. Client notified within 4 hours. 0n40i4 briefed within 1 hour. Forensic investigation initiated.
- Access
- Strictly need-to-know. Data minimization enforced at collection. Pseudonymization where possible.
- Logging
- Every access event logged with purpose justification. Quarterly access review mandatory. Logs retained per GDPR (typically 36 months).
- Deletion Procedure
- Subject Access Request (SAR) honored within 30 days. Right to erasure enforced across all systems, backups, and third-party processors.
- Breach Protocol
- GDPR Art. 33 compliance: supervisory authority notified within 72 hours. Data subjects notified if high risk (Art. 34). Full incident report within 14 days.
- Access
- Finance team, FinRep, CNCFinCtrl, 0n40i4. Segregation of duties enforced (no single user can create + approve).
- Logging
- Tamper-proof audit log. Every transaction recorded with full lineage. Logs retained 7 years.
- Deletion Procedure
- Not permitted during statutory retention period (5 years). Post-retention: approved by 0n40i4 + legal counsel. Certified destruction.
- Breach Protocol
- Immediate freeze of affected accounts/records. Forensic audit within 48 hours. Regulatory notification per applicable financial regulation.
- Access
- Per regulatory framework (HIPAA, PSD2, etc.). Access controls defined in client-specific DPA. K0nsult acts as processor only.
- Logging
- Per regulation. Minimum: full audit trail with non-repudiation. Client receives log access.
- Deletion Procedure
- Per regulatory retention schedule. Client controls deletion timeline. K0nsult confirms destruction within 30 days of instruction.
- Breach Protocol
- Per sector regulation (e.g., 24h for PSD2, 72h for GDPR). Client is primary notifier to regulator. K0nsult provides full support and forensic data.
- Access
- ML engineering team, K02, authorized agents. No raw PII — all data anonymized before ingestion into training pipelines.
- Logging
- Dataset version control. Provenance tracking for all training inputs. Bias audit logs retained 24 months.
- Deletion Procedure
- Datasets purged after 12 months or upon client withdrawal of consent, whichever is earlier. Model retraining triggered if significant data removed.
- Breach Protocol
- Assess if anonymization was compromised. If re-identification possible, escalate to PII breach protocol. Notify affected clients within 24 hours.
3. Universal Breach Response Protocol
Regardless of data category, the following master protocol applies upon detection of any suspected or confirmed breach:
- Detect & Contain — Isolate affected systems. Preserve forensic evidence. Revoke compromised credentials immediately.
- Classify — Determine data categories involved, volume of records, and geographic scope.
- Escalate — Notify K02 (immediate), 0n40i4 (within 1 hour), legal counsel (within 2 hours).
- Notify — Supervisory authority within 72 hours (GDPR). Affected data subjects if high risk. Client within 4 hours.
- Investigate — Root cause analysis. Timeline reconstruction. Attack vector identification.
- Remediate — Patch vulnerability. Update access controls. Retrain staff if human error.
- Report — Full incident report within 14 days. Lessons learned distributed to all stakeholders.
- Review — Post-incident review at 30 and 90 days. Update Data Classification Standard if gaps identified.
4. Access Control Summary
| Category |
Authentication |
Authorization |
Encryption |
Audit Frequency |
| Public |
None required |
Open |
Optional (TLS recommended) |
N/A |
| Internal |
SSO + MFA |
Role-based (RBAC) |
TLS 1.3 in transit |
Quarterly |
| Confidential |
SSO + MFA + device trust |
Named-user ACL |
AES-256 at rest + TLS 1.3 |
Monthly |
| PII |
SSO + MFA + device trust |
Named-user + purpose limitation |
AES-256 at rest + TLS 1.3 |
Monthly + quarterly SAR review |
| Financial |
SSO + MFA + IP restriction |
Segregated duties (SoD) |
AES-256 + HSM key management |
Monthly |
| Regulated |
Per regulation |
Per regulation + client DPA |
Per regulation (minimum AES-256) |
Per regulation |
| Training |
SSO + MFA |
ML team RBAC |
AES-256 at rest + TLS 1.3 |
Quarterly + bias audit |
5. Governance & Review
| Activity | Frequency | Owner |
| Data classification review | Semi-annually | K02 + DPO (Kai) |
| Access control audit | Quarterly | CNCAudit (Fatima) |
| Breach response drill | Annually | K02 + Watch (BCM) |
| Retention compliance check | Quarterly | CNCLegal (Rodrigo) |
| Training data anonymization audit | Semi-annually | CNCTech (Aiko) |