Skip to main content

Application Risk Classification Policy

1. Objective​

This policy defines the mandatory application risk classification model adopted by the organisation, based on the SbD-ToE model.

Risk classification is the entry point for the proportional application of security controls. Without a formal, validated and traceable classification, it is not possible to ensure that the controls applied are appropriate to the technical and business context of each application.

The policy establishes:

  • The classification model to be used and its assessment axes;
  • The mandatory moments of application and reassessment;
  • The risk tier criteria (L1, L2, L3) and their implications;
  • The requirements for formal recording, approval and traceability.

2. Scope​

This policy applies to all applications developed, operated or contracted by the organisation, regardless of their nature (internal, external, public, API, backend service, product), technology or delivery model.

Classification must be carried out before development begins or, for existing applications without a prior classification, in the first review cycle after adoption of the SbD-ToE model.


3. Classification model - E+D+I axes​

Risk classification is based on the assessment of three independent axes:

AxisDesignationWhat it assesses
EExposureAttack surface and accessibility of the application
DDataSensitivity and volume of the data processed
IImpactConsequence of a security incident for the business and for third parties

The combined score of the three axes determines the overall criticality level of the application.

3.1 Risk tiers​

LevelGeneral descriptionTypical examples
L1Low risk - internal application, no sensitive data, limited impactInternal tools, dashboards without PII, utilities
L2Medium risk - public exposure or user data, moderate impactPublic APIs, applications with authentication, customer portals
L3High risk - regulated systems, PII, critical data, severe impactFinancial systems, healthcare, critical infrastructure, regulated data

3.2 Criteria per axis​

Axis E - Exposure:

ValueCriterion
LowAccess restricted to the internal network, no external exposure
MediumAuthenticated access by external users or partners
HighPublic access without authentication, or an API exposed to third parties

Axis D - Data:

ValueCriterion
LowNo personal data, no regulated data, no business secrets
MediumUsers' personal data, confidential business data
HighSensitive PII, regulated data (GDPR, health, financial), critical secrets

Axis I - Impact:

ValueCriterion
LowLimited operational impact; no consequences for third parties
MediumSignificant operational impact; possible reputational damage
HighCritical business impact; regulatory, legal or third-party consequences

3.3 Automation and decision-support contexts​

The use of automation or decision-support mechanisms (including AI systems) does not create new risk axes, but must be taken into account when it modifies relevant attributes of the existing risk, namely:

  • Introduction of a new exposure surface or external integration;
  • Additional processing of personal or regulated data, secrets or confidential information;
  • Increased delegation, reach or speed of decisions with real impact.

Whenever any of these conditions applies, the team must adjust the affected axes and explicitly record the rationale for the decision.


4. Mandatory moments of application​

MomentMandatory status
Start of a new project or productMandatory
Before the first deployment to production (go-live)Mandatory
After a significant architectural changeMandatory
After a new external integration or additional exposureMandatory
After a change to the type or volume of data processedMandatory
Periodic review with a defined cadenceMandatory
After a relevant security incidentMandatory

5. Periodic review cadence​

The classification must be reassessed at a minimum cadence defined per level:

LevelMinimum cadence
L1Annual (12 months)
L2Half-yearly (6 months)
L3Quarterly (3 months)

Each reassessment must document:

  • Reassessment of the three axes E, D and I based on the current state of the application
  • Decision: keep the level / change the level (with technical justification)
  • Date of the next scheduled review
  • Approval by the responsible AppSec Engineer

6. Classification process​

6.1 Mandatory steps​

  1. Apply the E+D+I model - assess each axis against the criteria defined in section 3
  2. Determine the overall level - L1, L2 or L3, based on the combined score
  3. Document the rationale - record the criteria that determined each axis and the final level
  4. Obtain validation - review and approval by an AppSec Engineer
  5. Record formally - versioned classification document, with date and owner
  6. Communicate to the teams - the level determines the mandatory controls to be applied across all SbD-ToE chapters

6.2 Approvals by level​

LevelMinimum approval required
L1Tech Lead or AppSec Engineer
L2AppSec Engineer
L3AppSec Engineer + CISO or equivalent

7. Formal recording and traceability​

Every classification and its reassessment must be:

  • Recorded in a versioned document, identified per application
  • Associated with the classification date and the person responsible for approval
  • Accessible for consultation by AppSec, GRC and auditors
  • Updated whenever the level changes, with history preserved

Main artefact: risk-classification.md (or equivalent in the project repository or in the organisation's GRC platform)


8. Implications of the classification​

The assigned risk level directly determines:

  • The active SbD-ToE chapters and the mandatory controls to be applied
  • The applicable organisational policies and their degree of mandatoriness
  • The security artefacts that must be produced and maintained
  • The required review and security testing cadences
  • The approval authorities for exceptions, deploys and risk changes
warning

An incorrect or outdated classification invalidates the proportionality of all the controls applied. Actively maintaining the classification is an ongoing responsibility of the team, not a one-off onboarding act.


9. Responsibilities​

RoleResponsibility
Tech Lead / Team LeadInitiate the classification process at project start-up
AppSec EngineerValidate and approve the classification; conduct periodic reassessments
DeveloperNotify technical changes with potential impact on the E, D or I axes
GRC / ComplianceEnsure that all applications have a recorded and up-to-date classification
CISOApproval of L3 classifications; oversight of the classification programme
Product ManagementReport business changes with an impact on the axes

10. Review and audit of this policy​

This policy must be reviewed annually or after any of the following events:

  • Change to the SbD-ToE classification model
  • Regulatory change that introduces new risk criteria
  • Incident that reveals a gap in the classification model

Evidence of the application of this policy (classification documents, reassessment history, approvals) must be auditable by GRC functions and by external auditors.


11. Normative and technical references​

ReferenceRelevance
SbD-ToE Ch. 01 - Application ClassificationE+D+I model, level criteria, classification user stories
SbD-ToE Ch. 14 - Governance and ContractingApproval authorities, organisational traceability
ISO/IEC 27001 - Clause 6.1Risk assessment and treatment
NIST SP 800-30Guide for Conducting Risk Assessments
OWASP Risk Rating MethodologyApplication risk assessment criteria
SSDF PW.1Risk-based definition of security requirements