Annex A 7.14: Secure Disposal Or Re Use Of Equipment

Annex A control 7.14 sits in the “physical controls” family, but most audit findings are not about shredders or recycling bins. They are about process gaps: missing chain-of-custody, inconsistent wiping, unclear ownership between IT and Facilities, weak oversight of IT asset disposition (ITAD) vendors, and no evidence that data was actually removed before equipment was reused or disposed. The risk is straightforward: sensitive information can persist on drives, copiers, mobile devices, network gear, removable media, or embedded storage, and that data can be recovered after the asset leaves your environment.

A CCO or GRC lead’s job here is to turn a broad control statement into a repeatable, evidenced control operation. You need a defined decision tree (wipe vs. destroy vs. return), a standard for “good enough” sanitization by asset type, and a documentation package that stands up to ISO 27001 certification assessment. This page gives you requirement-level implementation guidance you can hand to IT, Security, and Operations and then audit quickly.

Sources for framework context: ISO’s ISO/IEC 27001 overview and public Annex A summaries. ¹

Regulatory text

Framework requirement (excerpt/summary): “ISO/IEC 27001:2022 Annex A control 7.14 implementation expectation (Secure Disposal Or Re Use Of Equipment).” This is commonly summarized as “Annex A 7.14: Secure Disposal Or Re Use Of Equipment.” ¹

What the operator must do:
You must implement controls so that equipment is securely disposed or securely prepared for reuse. In practice, that means:

• identify when equipment is leaving your control or being reassigned;
• remove or render unrecoverable any information stored on the equipment (including embedded or removable storage);
• use approved methods appropriate to the data sensitivity and asset type; and
• keep records that prove the sanitization or destruction was completed.

This control is assessed based on design (policy + procedure + defined methods) and operating effectiveness (tickets, logs, certificates, chain-of-custody, and sampling evidence that matches reality).

Plain-English interpretation (what 7.14 is really testing)

Auditors are testing whether you can answer, with evidence: “Where did this asset go, what data might have been on it, what did we do to prevent recovery, and who verified it?”

If you have strong endpoint security but weak disposition controls, you still fail 7.14 because the risk event happens at the boundary: resale, recycling, return-to-lessor, e-waste pickups, repairs, and internal redeployments.

Who it applies to (entity and operational context)

Entity types: Any organization operating an ISMS under ISO/IEC 27001, especially service organizations handling customer data. ²

Operational contexts in scope:

• Employee endpoints (laptops, desktops, tablets, phones) including BYOD if the organization stores corporate data on the device.
• Servers, storage arrays, backup appliances, and lab gear.
• Network devices with storage (firewalls, routers, switches with flash).
• Printers/MFPs and scanners with internal drives.
• Removable media (USB, external drives, SD cards).
• “Non-obvious” storage: IoT devices, cameras, badge readers, conferencing systems, medical/industrial devices, and any gear with flash memory.

Third parties in scope: ITAD vendors, recyclers, repair depots, manufacturers handling RMAs, managed service providers, colocation providers, and lessors. If they touch equipment that may contain your information, they are in your control environment.

What you actually need to do (step-by-step)

Use this as the minimum operational workflow. Build it into your ITSM tool so the process cannot be bypassed.

1) Define disposition triggers and ownership

Create explicit triggers that require the 7.14 workflow:

• disposal (e-waste/recycling)
• resale/donation
• return-to-lessor
• internal redeploy / reassignment
• repair/RMA
• decommissioning servers or storage Assign owners:
• Process owner: Security or IT Asset Management
• Approver: Information Security (for exceptions), Asset Owner, and sometimes Legal/Privacy for regulated datasets
• Operator: IT operations, datacenter ops, or approved third party

2) Maintain a disposition-ready asset inventory

Your asset record needs, at minimum:

• unique asset ID / serial number
• asset type and storage components (internal drive, removable media, embedded flash)
• assigned user/owner and last known location
• data classification expectations (what could be on it based on use)
• disposition status (pending wipe, wiped, destroyed, transferred) If inventory is incomplete, your evidence will not reconcile during sampling.

3) Establish approved sanitization and destruction methods by asset type

Create a “methods matrix” that your operators can follow without debate. Example structure:

Asset category	Typical storage	Default action for reuse	Default action for disposal/exit
Laptops/desktops	SSD/HDD	verified wipe + reinstall	verified wipe or physical destruction (based on classification)
Servers/storage	HDD/SSD/NVMe	verified wipe + reimage	wipe or destruction; document per drive
MFP/printer	internal HDD/flash	factory reset + drive wipe	wipe/destruction of storage component
Mobile devices	flash	enterprise wipe + remove from MDM	wipe + confirm unenrollment
Removable media	USB/SD	wipe if permitted	destroy if unknown provenance or high sensitivity

Keep the matrix aligned to your internal data classification policy. The key is not the brand of tool; it is that the method is approved, repeatable, and evidenced.

4) Implement a “no transfer without closeout” gate

Make sanitization a required closeout step before:

• Facilities picks up e-waste
• a courier ships devices to a third party
• equipment is placed in surplus
• assets are reassigned to another employee/team
• an RMA leaves the building

A practical control: require an ITSM ticket with mandatory fields (asset ID, method, operator, date/time, verification result, destination, and evidence attachment) before any asset can be marked “disposed” or “redeployed.”

5) Verify completion (don’t accept “we wiped it”)

Verification should be proportional:

• For common endpoints, require wipe logs or tool output attached to the ticket.
• For physical destruction, require a destruction certificate that references serial numbers, plus chain-of-custody from pickup to destruction.
• For third-party processing, require a report listing each asset/drive by serial and final disposition, then reconcile it to your inventory.

6) Control third parties through contracts and oversight

Minimum expectations for third parties handling equipment:

• contract language requiring secure handling, sanitization/destruction, and reporting by serial number
• right to audit (or at least obtain audit reports)
• secure transport and chain-of-custody documentation
• prohibition on resale until sanitization is completed and evidenced Operationally, treat the third party as part of the control: their documentation becomes your audit evidence.

7) Capture recurring evidence (make it routine)

ISO assessments often fail on “we do it, but we can’t prove it.” Build recurring evidence capture:

• monthly sample review of disposition tickets vs. inventory
• quarterly reconciliation of ITAD certificates vs. shipped assets
• exception log review (lost devices, emergency replacements, failed wipes)

Daydream can help by mapping Annex A 7.14 to a documented control operation and setting a recurring evidence request cadence, so evidence is collected as work happens rather than reconstructed during audit.

Required evidence and artifacts to retain

Keep these artifacts centrally, with retention aligned to your ISMS record retention rules:

1. Policy and procedure

• Secure disposal/reuse procedure (including roles and triggers)
• Approved sanitization/destruction methods matrix
• Third-party handling requirements for equipment disposition

2. Operational records ²

• Disposition ticket (asset ID, serial, operator, method, verification)
• Wipe logs/tool outputs or screenshots (where applicable)
• Chain-of-custody forms (internal transfer, courier, third party)
• Certificates of destruction/sanitization listing serial numbers

3. Oversight records

• Vendor/third party due diligence package relevant to ITAD or repair vendors
• Reconciliation reports (inventory vs. certificates)
• Exception register and approvals (e.g., “cannot wipe due to failure; destroy drive”)

Common exam/audit questions and hangups

Expect questions like:

• “Show me evidence for a sample of disposed laptops from the last period. Where are the wipe logs or destruction certificates?”
• “How do you ensure printers/MFPs are included?”
• “What happens when a laptop is lost or stolen? How is that handled under your process?”
• “How do you prevent Facilities from disposing equipment outside the workflow?”
• “How do you control third parties that receive equipment for repair or recycling?”

Hangups that drive findings:

• certificates that don’t list serial numbers
• tickets that say “wiped” with no verification artifact
• inventory shows assets retired, but no chain-of-custody exists
• embedded storage overlooked (printers, network gear)

Frequent implementation mistakes and how to avoid them

1. Treating “disposal” as a Facilities task.
   Fix: require IT/security closeout before any physical removal.

2. Only controlling laptops, ignoring everything else.
   Fix: inventory categories must include printers, network gear, removable media, and specialty devices.

3. Relying on a third party without reconciling reports.
   Fix: reconcile serial numbers shipped vs. certificates received; escalate discrepancies.

4. No defined method selection.
   Fix: publish the methods matrix and train operators. If the method depends on classification, make the classification field mandatory.

5. Evidence created after the fact.
   Fix: make evidence attachments required fields in the ticketing workflow.

Enforcement context and risk implications

No public enforcement cases are provided for this specific ISO control in the source catalog. ISO 27001 is a certification standard rather than a regulator, so the practical “enforcement” mechanism is certification audit nonconformities, customer assurance failures, and contractual breaches tied to security requirements. ²

Risk implications remain concrete:

• data exposure from resold/recycled assets
• breach notifications and contractual damages if customer data is recovered
• loss of customer trust and failed security reviews during sales cycles

A practical 30/60/90-day execution plan

Use this to operationalize quickly without guessing timelines beyond the phases.

First 30 days (Immediate stabilization)

• Name an owner for equipment disposition (ITAM or Security).
• Document the disposal/reuse workflow in one page: triggers, required ticket fields, and approval points.
• Publish an approved methods matrix by asset type and data classification.
• Identify all third parties touching equipment disposition (ITAD, repair, lessor) and centralize contracts/SOWs.
• Start capturing evidence for every disposition event going forward, even if the process is imperfect.

Days 31–60 (Control hardening)

• Integrate the workflow into ITSM: mandatory asset ID, mandatory evidence attachment, required “verification” field.
• Expand asset inventory coverage to “easy-to-miss” equipment (MFPs, network gear, removable media).
• Implement chain-of-custody templates and require them for shipments.
• Run a reconciliation between inventory retirements and ITAD certificates; open issues for any mismatches.
• Train Service Desk, Desktop Support, Facilities, and Datacenter Ops on the new gate.

Days 61–90 (Assurance and audit readiness)

• Perform an internal sample test: pick recent disposition events and confirm end-to-end evidence exists and matches inventory.
• Formalize exception handling (failed wipe, damaged drive, emergency swap, lost device) with approvals and compensating actions.
• Review third-party performance: timeliness and completeness of reports, serial-level detail, discrepancy handling.
• Set a recurring evidence capture cadence and assign reviewers; Daydream can track the control, evidence requests, and gaps against Annex A 7.14.

Frequently Asked Questions

Does Annex A 7.14 apply to cloud infrastructure if we don’t own the hardware?

It applies to equipment you control and to third parties that process equipment on your behalf. For cloud, address it through third-party assurance and contract controls that cover media handling and sanitization expectations.

Are factory resets enough for laptops and phones?

Sometimes, but your control needs a defined approved method and verification evidence. For endpoints, auditors usually expect proof of sanitization (logs or tool output) tied to the asset record.

What about printers and copiers? We don’t track them well.

Printers/MFPs frequently contain storage. Bring them into the asset inventory, define sanitization steps for that device class, and require disposition tickets and evidence like any other asset.

How do we handle equipment sent out for repair (RMA) where the manufacturer wants the drive intact?

Treat it as an exception that requires security approval, documented risk acceptance, and compensating controls (for example, remove the drive first when possible, or require secure handling terms and chain-of-custody from the repair vendor).

What evidence do ISO auditors actually accept for third-party destruction?

They look for serial-number-level documentation, chain-of-custody, and reconciliation to your inventory. A generic “certificate of destruction” without identifiers often fails sampling.

We have multiple offices. How do we keep people from bypassing the process?

Put the gate in systems (ITSM + asset inventory) and in logistics (no pickups without ticket ID). Back it with training and periodic sampling to detect off-process disposal.

Footnotes

1. ISO/IEC 27001 overview; ISMS.online Annex A control index

2. ISO/IEC 27001 overview