PII return, transfer, and disposal controls

CCOs and GRC leads usually discover this control gap during customer due diligence: “If we terminate, how do you return our data, and how do you delete it everywhere?” ISO/IEC 27018 is aimed at public cloud PII processors, so auditors and enterprise customers expect crisp answers, not general security statements. The requirement is simple to state but hard to execute because PII sprawl is real. PII often exists in primary databases, object storage, analytics platforms, support tools, message queues, backups, and downstream subprocessors.

This page translates the pii return, transfer, and disposal controls requirement into a requirement-level, operator-friendly implementation plan. It focuses on contract end and customer-request scenarios: (1) returning or exporting PII in a usable format, (2) transferring PII securely to a new provider or back to the customer, and (3) securely disposing of PII with proof. You will also see what evidence to retain, the exam questions that stall teams, and a practical 30/60/90-day plan to get to a defensible baseline.

Regulatory text

What we can cite from the provided source catalog: “Baseline implementation-intent summary derived from publicly available framework overviews; licensed standard text is not reproduced in this record.” The requirement summary for ISO27018-10 is: “Support controlled PII return, transfer, and disposal at contract end.” ¹

Plain-English operator interpretation You need an offboarding capability that is:

1. Controlled: initiated by an authorized request, executed via a defined workflow, and tracked end-to-end.
2. Complete: covers all locations where the customer’s PII resides, including backups and subprocessors (or documents justified exceptions).
3. Verifiable: produces evidence that the PII was returned/transferred as requested and then deleted/disposed per contract and policy.

This is not just a security requirement. It is a lifecycle requirement: the customer’s PII must be handled predictably when the relationship ends.

Scope: who it applies to

Entity types

• Cloud PII processors (as summarized for ISO/IEC 27018) ¹

Operational contexts where this control is tested

• Contract termination (customer churn, non-renewal, breach exit, M&A, insolvency wind-down)
• Customer request for a data export or migration to a new provider
• Service decommissioning, product retirement, region shutdown
• Subprocessor changes that trigger return/transfer obligations downstream

Data in scope

• PII processed on behalf of the customer across production systems, backups, DR replicas, logs where PII is present, support tooling, and any third party/subprocessor systems that receive the PII.

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

Step 1: Define “end-of-contract” triggers and owners

Create a simple trigger model and ownership:

• Triggers: termination notice received, contract end date reached, customer submits “data return + delete” request, legal hold lifted.
• Owners: one accountable owner (often Security/GRC) plus execution owners (Ops/SRE, Data/Platform, Support, Legal/Privacy, Procurement for third parties).
• Decision authority: who can approve exports, who can authorize deletion, and who can grant exceptions (for example, legal retention).

Deliverable: an Offboarding RACI and a standard intake form (ticket template) for PII return/transfer/disposal.

Step 2: Build a PII “offboarding data map” that is deletion-ready

A normal data inventory is not enough. You need a map that answers: “Where does this customer’s PII exist, and can we isolate it?” Minimum fields:

• System name + environment (prod, staging if applicable)
• Storage type (DB, object store, logs, analytics)
• Customer/tenant keying method (tenant_id, customer partition, encryption key)
• Backup coverage (where, how long retained, how deletion works)
• Replication/DR notes (regions, snapshots)
• Downstream transfers (subprocessors, integrations)
• Export method (API export, bulk export, support-assisted)
• Deletion method (hard delete, crypto-shred, purge job)
• Evidence produced (logs, job output, attestation)

If you cannot map it, you cannot convincingly delete it. This is the most common reason teams fail diligence.

Step 3: Standardize return/export formats and secure transfer methods

Define what “return” and “transfer” mean in practice:

• Return/export: what format(s) you provide (CSV/JSON/Parquet), what schema documentation accompanies it, and how you handle attachments/blobs.
• Secure transfer: approved channels (customer-provided S3 bucket with encryption, SFTP with strong auth, pre-signed URL with short expiry, customer-managed key exchange).
• Chain-of-custody: who generated the export, where it was staged, how it was encrypted, who received it, and when access was removed.

Operational controls to implement:

• Require authenticated request + authorization (ticket plus customer identity verification).
• Use encryption in transit and at rest for staging locations.
• Time-bound access to exported packages and delete staging copies after delivery.

Step 4: Implement secure disposal that includes backups and subprocessors

“Disposal” needs a defined method and a defined verification path:

• Primary systems: delete customer records and derived datasets.
• Backups/snapshots: document whether you (a) support targeted deletion, (b) use crypto-erasure by retiring keys, or (c) rely on backup expiration with a stated retention period, subject to contract and law.
• Logs/telemetry: if PII is present, define redaction, retention, and purge approach.
• Subprocessors: flow down deletion/return obligations contractually and operationally. Your offboarding runbook should include notifying subprocessors and capturing their confirmations.

Practical point: many organizations can delete production data quickly but cannot speak clearly about backup and log realities. Auditors accept constraints if you document them, contract for them, and show a controlled process with defined retention and access controls.

Step 5: Add verification, approvals, and exceptions (so you can prove it)

Create a lightweight “evidence spine”:

• Approvals: export approval, deletion approval, exception approval (legal hold, regulatory retention, billing disputes).
• Execution records: job IDs, scripts run, system logs, admin activity logs, subprocessor tickets.
• Attestation: a completion statement that lists systems covered and states what was returned/transferred/deleted, and what was retained under exception.

If you run on tickets, make the ticket the system of record. Attach logs and sign-offs. If you run on automation, retain immutable logs.

Step 6: Test the workflow and train the teams who will execute it

Run an internal tabletop:

• Pick a real customer tenant (or synthetic tenant) and execute export + transfer + delete.
• Confirm you can identify all data stores, including “shadow” locations (support attachments, analytics extracts).
• Validate evidence capture.

Train Support and Customer Success on intake and expectations. They are the front door for these requests.

Required evidence and artifacts to retain

Keep artifacts that show both design and operation:

Design artifacts

• Policy or standard: PII lifecycle, offboarding, disposal standard
• Offboarding runbook (return/transfer/disposal)
• Data map focused on customer-level deletion and export points
• Subprocessor contract clauses or addenda covering return/deletion obligations (where applicable)
• Defined secure transfer procedures

Operational evidence

• Completed offboarding tickets with approvals and timestamps
• Export generation logs and checksums (if used), plus delivery confirmation
• Deletion job logs (or administrative audit logs) per system in scope
• Subprocessor deletion/return confirmations
• Exception register entries (legal holds, regulatory retention) with approver and scope
• Customer-facing completion attestation (template + sent copy)

Tip: store these in an audit collection by customer and by period, so you can answer diligence requests without a scramble.

Common exam/audit questions and hangups

Auditors and customer assessors often drill into these:

• “Show me the exact workflow you follow at termination, including approvals.”
• “Which systems contain our PII, and how do you delete it from each?”
• “What about backups, snapshots, and disaster recovery replicas?”
• “Do any logs contain PII? How do you control retention and access?”
• “Which third parties/subprocessors receive PII, and how do you ensure they delete it?”
• “Provide evidence from a recent offboarding event (redacted).”
• “How do you handle legal holds or statutory retention conflicts?”

Hangup pattern: teams answer conceptually (“we delete data”) but cannot produce system-by-system evidence.

Frequent implementation mistakes (and how to avoid them)

1. Only addressing production databases

   • Fix: expand scope to backups, analytics, support tooling, and downstream transfers. Maintain the offboarding data map.

2. No defined secure transfer pattern

   • Fix: pre-approve transfer methods and require encryption + time-bounded access. Document chain-of-custody.

3. Manual deletion with no logs

   • Fix: require deletion tickets, peer review for destructive actions, and capture system logs or admin audit trails.

4. Subprocessors forgotten at offboarding

   • Fix: add a subprocessor step to the runbook and require confirmations. Procurement and Security should share accountability.

5. Exceptions handled informally

   • Fix: create an exception register with scope, rationale, approver, and revisit triggers (for example, when a legal hold ends).

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this page does not cite specific actions.

Operational risk still concentrates in predictable places:

• Breach exposure: retained PII after contract end expands the blast radius if you have an incident.
• Contract and trust impact: enterprise customers often treat offboarding and deletion proof as a gating control for onboarding and renewals.
• Audit outcomes: inability to produce evidence tends to be written up as a control operating effectiveness gap, even if teams “usually” delete data.

Practical 30/60/90-day execution plan

First 30 days: get to a documented, repeatable baseline

• Assign an owner and publish a simple RACI for offboarding.
• Draft the offboarding runbook: intake, approvals, export/transfer, deletion, evidence.
• Identify top PII systems and create the first version of the offboarding data map.
• Create templates: customer request intake, deletion approval, completion attestation, exception record.

Days 31–60: make it real with system coverage and evidence

• Expand mapping to backups, replicas, analytics, logs, and support tooling.
• Implement or standardize secure transfer options and staging controls.
• Add subprocessor offboarding steps and confirmation tracking.
• Run one internal test offboarding and capture the evidence package end-to-end.

Days 61–90: operationalize and measure

• Train Support/CS and Operations on the workflow and intake criteria.
• Automate repeatable exports and deletion jobs where feasible; ensure logs are retained.
• Add periodic reviews: sample recent offboarding cases and validate evidence completeness.
• Prepare an “audit pack” that includes the runbook, data map, and redacted completed examples.

Where Daydream fits naturally If you’re coordinating offboarding across multiple systems and third parties, Daydream can act as the control workspace: standard ticket templates, evidence checklists, exception tracking, and an audit-ready folder structure per customer termination event. The goal is not more process. The goal is fewer “we think it was deleted” moments.

Frequently Asked Questions

Do we have to delete PII from backups immediately at contract end?

ISO/IEC 27018 expects controlled disposal at contract end, but your method can vary by architecture ¹. If you rely on backup expiration or crypto-erasure, document it, limit access, and capture evidence that the customer’s PII will not be restored into production outside the workflow.

What evidence is strongest for proving deletion?

System-generated logs are strongest: deletion job outputs, admin audit logs, and immutable event trails tied to a ticket or change record. Pair that with a completion attestation that lists in-scope systems and any exceptions.

How do we handle legal holds or statutory retention that prevent deletion?

Treat it as an approved exception with scope (which data), rationale (legal hold), controls (restricted access), and a revisit trigger (hold released). Your customer communication should distinguish “deleted” from “retained under legal obligation.”

What if the customer asks for a transfer to a new provider?

Use a secure transfer method you can control and evidence: encrypted export, authenticated delivery, and documented chain-of-custody. Remove access to any staging locations after confirmation of receipt.

Do we need a customer-facing certificate of destruction?

Many customers expect an attestation even if they don’t call it that. Provide a standard statement that describes what was returned, what was deleted, where exceptions apply (for example, backups under retention), and the completion date.

How do we manage subprocessors during offboarding?

Your runbook must include subprocessor notification and confirmation collection, aligned to your subprocessor inventory. If a subprocessor cannot confirm deletion, document the gap and address it contractually or operationally.

Related compliance topics

• 2025 SEC Marketing Rule Examination Focus Areas
• Access and identity controls
• Access Control (AC)
• Access control and identity discipline
• Access control lifecycle management

Footnotes

1. ISO/IEC 27018 overview