C1.2 Confidential information is disposed of securely
Disposes of confidential information to meet the entity's objectives related to confidentiality.
5
artefacts
1
held by a system
3
at each review
hard
to go live
Data governance / DLP tooling
where the evidence lives
teal = a system already holds it · olive = produced at each review
system holds itEvidence a system already holds
- Certificates or records from any third party performing destruction, reconciled at item level · Vendor register / contract repository
periodic reviewEvidence produced at each review
- Records of disposal performed in the period, showing what was disposed of, when and by what method · Data governance / DLP tooling
- Evidence disposal covers all copies, including backups, archives, replicas and third party held copies · Backup / DR tooling
- Evidence of verification that disposal was effective and that the information is no longer recoverable · Data governance / DLP tooling
governing documentDocuments that govern the control
- The disposal procedure for confidential information, defining the method per medium and per system · Policy repository / GRC workspace
First move
Mostly documents and reviews. Pull the 1 system-held artefact from your Vendor register / contract repository on a schedule; put the documents under version control with an owner and review date, and log each review as a dated record with a named reviewer.
Common gaps auditors find
- Retention periods defined and never enforced, so nothing is actually disposed of
- Disposal performed in the primary system while backups retain the information beyond the committed period
- Third party destruction certificates accepted with no reconciliation to what was sent
- Logical deletion treated as disposal, leaving the data present and recoverable
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 sheetC1.1 Confidential information is identified and protected during receipt, processing, storage · CC1.1 COSO principle 1: Demonstrates commitment to integrity and ethical values