Annex A 8.10: Information Deletion

Annex a 8.10: information deletion requirement means you must define, implement, and prove a controlled process to delete information when it is no longer required, including copies in systems, media, and third-party environments. Operationalize it by mapping where data lives, setting deletion triggers, using approved deletion methods, and retaining evidence that deletions occurred as designed. ^{1 2}

Key takeaways:

• Define “what gets deleted, when, by whom, and how” for each major data store and lifecycle stage. ²
• Deletion must cover production, backups where feasible, endpoints, cloud services, and third parties, with risk-based exceptions documented. ¹
• Auditors will look for repeatable execution and evidence (tickets, logs, certificates of destruction, and exception approvals), not policy language. ²

Information deletion is an operational control, not a paper policy. Annex A 8.10 expects you to ensure information is deleted when it should be, and that the deletion is performed in a controlled, verifiable way aligned to your ISMS. The control becomes high-friction in real environments because data is duplicated across SaaS apps, collaboration tools, endpoints, logging systems, data warehouses, and backup platforms. A “delete button” in one system rarely equals complete deletion across the lifecycle.

For a Compliance Officer, CCO, or GRC lead, the fastest path is to treat deletion as a lifecycle requirement with clear triggers (retention expiry, contract termination, account closure, end of purpose), defined methods (logical deletion, secure overwrite, cryptographic erasure, physical destruction), and measurable evidence. You also need a clear exception path for legal holds, regulatory retention, security investigations, or technical constraints. Annex a 8.10: information deletion requirement is typically assessed through interviews, process walkthroughs, and sampling of completed deletions across a few representative systems. ^{1 2}

Regulatory text

Excerpt (provided): “ISO/IEC 27001:2022 Annex A control 8.10 implementation expectation (Information Deletion).” ¹
Summary (provided): “Annex A 8.10: Information Deletion.” ²

Operator interpretation (what you must do):

• Establish rules and procedures for deleting information when it is no longer needed, and make deletion a managed process that is performed consistently. ²
• Make the scope practical: deletion must address where information actually resides (applications, storage, backups, endpoints, removable media, and third parties) and how your organization verifies completion. ¹
• Keep evidence that the process is operating. Auditors will sample deletions and expect traceability from trigger → approval (if needed) → execution → verification → closure. ²

Plain-English requirement (annex a 8.10: information deletion requirement)

You need a repeatable process to delete information securely and on time, based on defined retention and business rules, and you must be able to prove it happened. “Securely” means deletion methods match the sensitivity of the data and the medium it sits on (cloud, disk, tape, device, paper). “On time” means deletion happens when a trigger occurs, unless a documented exception applies (for example, legal hold or required retention).

Who it applies to

Entities: Service organizations implementing or certifying an ISMS to ISO/IEC 27001. ¹

Operational context where this control bites:

• You process personal data, customer content, regulated records, or sensitive internal data.
• You use SaaS tools where your admins cannot truly erase underlying storage, and must rely on provider deletion features and contracts.
• You keep long-lived backups, immutable logs, or archive systems where deletion is constrained.
• You have third parties handling data (subprocessors, managed service providers, payroll, call centers, cloud hosting).

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

1) Define deletion scope and ownership

1. Name an owner for the deletion program (often Security/GRC with IT Ops and Data Owners executing).
2. Define information classes (at minimum: public, internal, confidential/restricted) and connect them to deletion handling expectations.
3. Set system boundaries: production systems, analytics, logs, endpoints, shared drives, collaboration tools, backups, paper records, removable media, and third-party systems.

Deliverable: Information Deletion Standard (or section within a Data Lifecycle Standard) that states triggers, methods, roles, and evidence.

2) Create a “system deletion matrix” (the control becomes real here)

Build a table for your highest-risk and highest-volume repositories first.

Minimum columns to include:

• System / repository name
• Data types stored (customer content, HR, finance, security logs)
• Data owner
• Deletion trigger(s): retention expiry, termination, user request (if applicable), contract end
• Deletion method: native delete, secure erase/overwrite, crypto-erase, physical destruction
• Backup impact: “expires naturally,” “selective deletion supported,” or “exception with rationale”
• Verification method: log entry, screenshot, audit log export, provider attestation
• SLA/target (express qualitatively if you cannot commit to a numeric SLA)

Why auditors care: This matrix proves you understand where information exists and how deletion is executed per environment. ²

3) Align deletion triggers to retention and legal hold

Deletion should not be an ad hoc admin action. Tie it to:

• Records retention schedule (business + regulatory needs)
• Contractual requirements (customer contracts, DPAs)
• Legal hold process (suspends deletion for defined data sets)
• Security incident needs (temporary retention for investigations)

Control point: Every deletion exception needs documented approval and a review point to remove the exception when the reason ends.

4) Implement deletion workflows (automate where possible)

Use your ticketing/workflow tool to enforce consistency:

1. Intake: request generated by trigger (scheduled job, HR offboarding, app deprovisioning, retention run).
2. Approval: required for high-risk systems or bulk deletions (data owner + security).
3. Execution: runbook steps per system (admin console actions, scripts, storage key destruction, device wipe).
4. Verification: attach evidence (audit log export, command output, destruction certificate).
5. Closure: reviewer signs off; exceptions recorded.

Practical tip: Put the runbook link inside the ticket template so the operator cannot “freestyle” the deletion.

5) Address backups and immutable stores explicitly

Backups are where many teams fail annex a 8.10: information deletion requirement. You need a position that is:

• Technically accurate for each backup platform (selective delete vs retention expiry).
• Risk-based: define what is acceptable for each data classification.
• Contract-aware: what your cloud/backup provider commits to.

If selective deletion is not feasible, document:

• The retention period and why
• Compensating controls (access restrictions, encryption, key management, monitoring)
• The trigger for ultimate deletion (backup expiry or media rotation)
• How you respond to customer deletion requests (if applicable) with clear, truthful language

6) Extend deletion to third parties

For third parties handling your information:

• Contract language should specify deletion/return at termination and deletion timelines where feasible.
• Require a deletion attestation or equivalent evidence at offboarding.
• Ensure your offboarding checklist includes “downstream deletion confirmation.”

If you use Daydream for third-party risk management, map deletion obligations as a standard contract and offboarding control, then track attestations and evidence in the third-party record so audit sampling is fast and consistent.

7) Run a test and operationalize recurring evidence capture

• Perform a controlled “deletion drill” for a small set of data across representative systems.
• Capture evidence exactly as an auditor would expect to see it.
• Schedule recurring deletion jobs (or recurring reviews) and collect artifacts each cycle.

This aligns with the recommended practice to document control operation and capture recurring evidence for 8.10. ²

Required evidence and artifacts to retain

Keep artifacts that show design and operation:

Design evidence

• Information Deletion Policy/Standard and system deletion matrix
• Records retention schedule and legal hold procedure
• Data inventory / data map (at least for in-scope systems)
• Third-party contract clauses and offboarding requirements (as applicable)

Operating evidence (sample-ready)

• Deletion tickets with timestamps and approver identity
• System audit logs showing deletion actions
• Script outputs or job run logs (where scripts are used)
• Certificates of destruction for media and paper
• Deprovisioning logs (SaaS accounts, endpoints)
• Exception register (legal holds, technical constraints) with approvals and review notes

Common exam/audit questions and hangups

Auditors commonly probe these points:

• “Show me three recent deletions end-to-end, including verification.”
• “How do you know deleted information is not still accessible somewhere else?”
• “What happens in backups and archives?”
• “How do you stop deletion during legal hold?”
• “How do you handle deletion at third parties after contract termination?”
• “Who approves high-risk deletions and bulk actions?”

Hangups that slow assessments:

• No system-level deletion matrix, only a generic policy
• Lack of verification evidence (operators say they deleted, but cannot prove it)
• Backups treated as out-of-scope without a documented rationale

Frequent implementation mistakes (and how to avoid them)

1. Mistake: Confusing retention with deletion.
   Fix: Retention defines “keep until,” deletion defines “remove after,” with a workflow and evidence.

2. Mistake: Relying on UI deletion without verification.
   Fix: Require audit-log confirmation or administrative reports as closure criteria.

3. Mistake: Ignoring derived data and duplicates.
   Fix: Identify common replication paths: exports, email attachments, BI extracts, logs, and data warehouses. Add deletion steps or retention controls for each.

4. Mistake: Treating backups as a blind spot.
   Fix: Document a backup deletion stance per platform and data class; include compensating controls and truthful customer communications.

5. Mistake: Forgetting third-party deletion at offboarding.
   Fix: Make deletion attestation a gated step in third-party offboarding.

Enforcement context and risk implications

ISO/IEC 27001 is a certifiable standard rather than a regulator, so “enforcement” usually shows up as certification nonconformities, surveillance audit findings, customer contract failures, or failed security reviews. Weak deletion control increases real risk: unnecessary data retention increases breach impact, increases eDiscovery scope, and creates contract noncompliance exposure when customers require deletion at end of service. ¹

Practical 30/60/90-day execution plan

First 30 days (foundation and scoping)

• Assign control owner and define RACI for deletion actions.
• Draft or update the Information Deletion Standard and exception handling.
• Build the first version of the system deletion matrix for your highest-risk systems.
• Choose evidence standards: what screenshots/log exports count, where stored, naming conventions.

By 60 days (implementation in core systems)

• Implement ticket templates and runbooks for the priority repositories.
• Integrate deletion triggers with offboarding and retention events.
• Add legal hold gating so holds suspend deletion consistently.
• Update third-party offboarding checklist to require deletion/return confirmation.

By 90 days (prove operation and make it repeatable)

• Run deletion drill(s) and fix gaps found in verification and backups.
• Start recurring evidence capture (sample a set of deletions each cycle).
• Hold a control review with IT, Security, and Data Owners; update matrix and runbooks based on operational reality.
• If you manage third-party risk in Daydream, centralize deletion attestations, contracts, and offboarding evidence so audit sampling is one query, not a scramble.

Frequently Asked Questions

Does Annex A 8.10 require “secure wipe” for every deletion?

No single method fits every medium. Define approved methods by data classification and storage type, then document and prove you follow those methods for each system. ²

How do we handle deletion from backups if selective deletion is not supported?

Document the backup retention and deletion mechanism (for example, expiry/rotation), restrict access, and record an exception rationale with compensating controls. Auditors mainly want transparency and consistent operation backed by evidence. ¹

What evidence is usually sufficient to prove a deletion occurred?

A closed ticket tied to a trigger plus system-generated proof works well: audit log export, admin report, job run log, or a certificate of destruction for media. Evidence should be reproducible and reviewer-verifiable. ²

Do we need to delete logs for security and fraud monitoring?

Treat security logs as records with a defined retention period and access controls. Delete them according to that schedule unless a legal hold or investigation requires extended retention, and document the exception.

How do we operationalize deletion for SaaS tools where we can only deactivate accounts?

Separate deprovisioning from deletion. Document what the SaaS provider’s delete function does, how you invoke it, and what verification you can obtain (audit logs or provider attestation), then reflect that in the system deletion matrix.

What is the fastest way to get audit-ready for this control?

Build the system deletion matrix for a small set of critical systems, implement a ticketed workflow with verification, and collect a clean sample set of completed deletions with artifacts. Expand coverage iteratively after the first assessment cycle. ²

Footnotes

1. ISO/IEC 27001 overview

2. ISMS.online Annex A control index