7.4.5 PII de-identification and deletion at the end of processing
The organization must delete personal data, or render it into a form that does not permit identification or re-identification of the individual, as soon as the original data is no longer necessary for the identified purp
5
artefacts
0
held by a system
4
at each review
hard
to go live
Document repository
where the evidence lives
teal = a system already holds it · olive = produced at each review
system holds itEvidence a system already holds
none for this control
periodic reviewEvidence produced at each review
- Deletion or de-identification mechanisms with evidence of operation · Document repository
- Assessment that de-identified output cannot reasonably be re-identified · Document repository
- Evidence the mechanisms reach every copy including backups, archives and derived datasets · Backup / DR tooling
- Records of deletions or de-identifications performed · Document repository
governing documentDocuments that govern the control
- Documented end of processing triggers per purpose · Document repository
First move
This control is evidenced by people and documents, not systems. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date. Do not try to automate it.
Common gaps auditors find
- End of processing never determined, so nothing ever triggers deletion
- Deletion in the application only, with the same data intact in warehouses, backups and exports
- De-identification relied on without testing, so the data remains re-identifiable and the obligation unmet
- Manual deletion processes that do not run at the volumes involved
- No record of deletion, so the organization cannot prove it happened
Do this for your whole sheet
Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.
Build my evidence sheet