What evidence do auditors commonly ask for on A.1.4.6 PII de-identification and deletion at the end of processing?

Documented end of processing triggers per purpose; Deletion or de-identification mechanisms with evidence of operation; Assessment that de-identified output cannot reasonably be re-identified; Evidence the mechanisms reach every copy including backups, archives and derived datasets; Records of deletions or de-identifications performed.

What is the most common gap auditors find on A.1.4.6?

End of processing never determined, so nothing ever triggers deletion

ISO/IEC 27701:2025 · Annex A Table A.1 PIMS controls for PII controllers

`A.1.4.6` PII de-identification and deletion at the end of processing

When the identified purposes stop requiring the original personal data, the organization must erase it or convert it into a form from which the individual cannot be identified, or identified again. It must have ways to erase data when no more processing is expected; de-identification is an acceptable substitute only while the result cannot reasonably be used to re-identify anyone.

Source: ISO/IEC 27701:2025, A.1.4.6. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open ISO/IEC 27701:2025 in the compliance library.

artefacts

held by a system

at each review

hard

to go live

Document repository

where the evidence lives

teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

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

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

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

A.1.4.5 PII minimization objectives · A.1.4.7 Temporary files