EvidenceSheet

A.1.4.9 Disposal

The organization must have documented policies, procedures or mechanisms for getting rid of personal data. It must pick disposal methods with regard to, among other things, what the data is and how much of it there is, any metadata linked to it, and the physical nature of the storage media, because methods vary in how they behave and what they leave behind, for example how finely the media ends up broken down or whether erased information can be recovered.

Source: ISO/IEC 27701:2025, A.1.4.9. 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.

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. 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

  • 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

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

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.

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A.1.4.8 Retention · A.1.4.10 PII transmission controls