7.4.8 Disposal
The organization must hold documented policies, procedures or mechanisms for the disposal of personal data, choosing disposal techniques with regard to factors including the nature and extent of the data, any associated
4
artefacts
0
held by a system
2
at each review
hard
to go live
Policy repository / GRC workspace
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
- Disposal records identifying what was disposed of, when, by whom and by what method · Data governance / DLP tooling
- Assurance evidence where disposal is performed by a third party · Vendor register / contract repository
governing documentDocuments that govern the control
- Disposal policy naming the technique used per media type and data category · Policy repository / GRC workspace
- Consideration of associated metadata in the disposal decision · Policy repository / GRC workspace
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
- One disposal method assumed adequate across all media, ignoring how outcomes differ
- Metadata such as filenames, indexes and audit trails surviving disposal of the data itself
- Third party disposal accepted on a certificate that does not identify the items destroyed
- Cloud held data disposed of by deleting a pointer, with the underlying storage untouched
- Disposal policy written for physical media only while most data is electronic
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