EvidenceSheet

A.2.4.3 Return, transfer or disposal of PII

The organization must be able to return, transfer or dispose of personal data securely and must share its policy on this with the customer. It must handle the capability securely whatever the outcome: handing the data back to the customer, passing it to another organization or controller, deleting, destroying, de-identifying or archiving it. It must give the customer the assurance it needs that data handled under the contract is wiped, by the organization and by its subcontractors, from every place it is held, backup and continuity copies included, once the customer's identified purposes no longer need it. The policy must state how long data is kept after the contract ends before disposal, so that the customer does not lose data because of an accidental lapse.

Source: ISO/IEC 27701:2025, A.2.4.3. 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.

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. 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

  • 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

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.

Build my evidence sheet

A.2.4.2 Temporary files · A.2.4.4 PII transmission controls