8.4.2 Return, transfer or disposal of PII
The organization must provide the ability to return, transfer or dispose of personal data securely and must make its policy available to the customer, managing the capability securely whether the outcome is return to the
5
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
- Assurance evidence that erasure reaches backups, continuity copies and subcontractors · Backup / DR tooling
- Records of returns, transfers and disposals performed, per customer · Data governance / DLP tooling
governing documentDocuments that govern the control
- Documented return, transfer and disposal policy, made available to customers · Policy repository / GRC workspace
- Stated post termination retention period before disposal, with its rationale · HR system / LMS
- Contractual flow down obliging subcontractors to erase on the same terms · 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
- Erasure certified for primary systems while backups retain the data for the full backup cycle, which the customer is not told
- Subcontractor copies unaddressed, so erasure assurance is given for data the organization does not control
- No post termination grace period, so an administrative lapse destroys the customer's data
- Grace period indefinite, so terminated customers' data is retained without basis
- Policy held internally and never made available to the customer
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