What evidence do auditors commonly ask for on A.3.21 Secure disposal or re-use of equipment?

Sanitisation procedure for equipment and storage before re-use or disposal; Records of sanitisation or destruction per device; Technical measures applied where explicit erasure is impractical, for example encryption with key destruction.

What is the most common gap auditors find on A.3.21?

Equipment resold or returned to lessors with storage intact

ISO/IEC 27701:2025 · Annex A Table A.3 information security controls with PII-specific guidance

`A.3.21` Secure disposal or re-use of equipment

Whenever storage space is re-assigned the organization shall ensure that any PII previously residing on it is not accessible, using specific technical measures where deletion of PII in an information system cannot practically be made explicit for performance reasons and another user could otherwise access it, and for disposal or re-use it shall treat equipment containing storage media that could possibly contain PII as though it does contain PII.

Source: ISO/IEC 27701:2025, A.3.21. 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

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

Records of sanitisation or destruction per device · Endpoint management (MDM / EDR)

governing documentDocuments that govern the control

Sanitisation procedure for equipment and storage before re-use or disposal · Policy repository / GRC workspace
Technical measures applied where explicit erasure is impractical, for example encryption with key destruction · 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

Equipment resold or returned to lessors with storage intact
Cloud or virtual storage re-assigned with no measure against residual PII

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.3.20 Storage media · A.3.22 User endpoint devices