Restriction of creation of hardcopy material

ISO/IEC 27018 Annex A.11.2 requires you to restrict the creation of any hardcopy that displays PII, which means printing must be explicitly authorized, technically controlled, and operationally monitored. To operationalize it, you need a documented “print-by-exception” rule, enforceable print controls, secure handling and disposal procedures, and evidence that exceptions are approved and traceable. ¹

Key takeaways:

• Treat printing as a controlled exception, not a default capability, for systems handling PII.
• Combine policy + technical controls (print restrictions, secure release) + physical controls (storage, shredding, clean desk).
• Keep audit-ready evidence: approvals, printer configs, logs, and disposal records tied to PII handling.

“Restriction of creation of hardcopy material” is easy to misunderstand because it sounds like a simple policy statement (“don’t print PII”). For a CCO or GRC lead, the requirement is operational: you must prevent uncontrolled physical copies of PII from being created, moved, or discarded outside your governance. Once PII is printed, normal cloud-native controls (access logging, encryption at rest, retention policies) stop applying. The risk shifts to physical theft, mishandling, and disposal failures.

ISO/IEC 27018 targets public cloud PII processors, so this control matters most where your organization processes customer PII in cloud services and where employees, contractors, or third parties can print tickets, reports, case notes, call logs, screenshots, exports, or customer records. It also applies to “shadow” printing paths like browser print dialogs, PDF exports that get printed later, and support workflows that generate hardcopy during incident response or customer verification.

A workable implementation starts with a tight rule: printing PII is prohibited unless there is a defined business need, an approved exception, and a controlled printing mechanism. Then you prove it with logs, approvals, and physical handling procedures.

Regulatory text

Requirement (verbatim): “The creation of hardcopy material displaying PII shall be restricted.” ¹

Operator meaning: You must put controls in place so that employees and third parties cannot freely print PII. “Restricted” needs to show up in (1) documented rules, (2) enforced technical configurations, (3) monitored operations, and (4) controlled physical handling from print to disposal.

Plain-English interpretation (what auditors expect you to mean)

Printing PII creates unmanaged copies. This requirement expects you to:

• Reduce printing of PII to the minimum necessary for business.
• Control who can print, what can be printed, and where it can be printed.
• Track printing activity enough to investigate suspected mishandling.
• Protect printed pages with physical security and secure disposal.

A practical interpretation that holds up in audits: “PII printing is prohibited by default; approved roles may print only through managed printers with secure release, and printed PII is handled and destroyed under documented procedures.”

Who it applies to (entity and operational context)

In scope entities

• Cloud Service Providers acting as PII processors (the ISO/IEC 27018 context). ¹

In scope operations and workflows

Focus on places where PII is viewed and could be printed:

• Customer support / service desk (tickets, identity verification notes)
• HR and people operations (candidate and employee records, if you process them as a service)
• Security operations and incident response (investigation notes, user lists)
• Finance and billing operations (invoices containing personal data)
• Engineering and data teams (exports, debug logs, database query results)
• Any third party onsite (outsourced support, consultants) with access to PII-bearing systems

Out of scope (or lower risk) examples

• Printing fully anonymized or properly de-identified data (only if you can demonstrate it does not display PII)
• Synthetic test data that contains no real PII

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

Step 1: Set the hard rule and define “PII printing”

Create a short policy standard that answers:

• What counts as “hardcopy material displaying PII” (screenshots printed, PDF reports, call notes, exports).
• Default position: prohibited unless approved.
• Where printing is allowed (specific sites/printers) and prohibited (home printers, personal devices).
• Handling requirements: secure pickup, storage, transport, disposal.

Make the policy enforceable: tie it to disciplinary standards and third-party contractual requirements where relevant.

Step 2: Identify print paths and prioritize your highest-risk systems

Build a simple inventory:

• Systems that display PII (CRM, case management, admin consoles, BI dashboards).
• Who accesses them (roles, teams, third parties).
• How printing can happen (browser print, application “export to PDF,” OS-level print, remote desktop printing).

A common operational move: start with the top PII-heavy systems and the teams most likely to print (support, operations), then broaden.

Step 3: Implement “print-by-exception” access controls

Controls that usually satisfy auditors:

• Role-based access: Only specific roles can print from PII systems.
• Manager/Compliance approval workflow: Named approver, documented business justification, time-bound or reviewed exceptions.
• Least privilege: If someone can do the job without printing, remove print permission.

If your environment uses central identity, tie printing permissions to groups that are reviewed as part of access recertification (keep it simple: “PII-Print-Approved”).

Step 4: Enforce technical restrictions on printing

Pick controls that fit how your users work:

• Endpoint controls: disable printing for high-risk apps, block local printer mapping in virtual desktops, restrict USB printing paths.
• Managed print services: require authenticated print release (badge/PIN) so pages don’t sit in output trays.
• Printer allowlisting: printing only to managed devices in controlled locations; block home/personal printers for corporate devices.
• Watermarking or headers (optional but strong): user ID, timestamp, classification (“Confidential—PII”) on printouts to increase accountability.

What auditors care about: you can demonstrate that restrictions are not “honor system” only.

Step 5: Put physical handling controls around the allowed printing

Once printing is allowed, control the lifecycle:

• Secure pickup: user must release the job physically; no unattended printing.
• Clean desk expectations: PII printouts are never left on desks, in conference rooms, or in unlocked cabinets.
• Storage: locked cabinets or secure rooms for any retention.
• Transport: sealed envelope; avoid casual movement between locations.
• Disposal: cross-cut shredding or certified destruction bins; prohibit disposal in normal trash.

Step 6: Logging, monitoring, and investigations

Define what “good enough” monitoring looks like:

• Log print jobs from managed printers (user identity, time, printer, job name if available).
• Review logs based on triggers: unusually high volume, printing outside normal hours, printing from sensitive applications.
• Incident playbooks: what to do if a printout is lost, found unattended, or suspected stolen.

Step 7: Extend the control to third parties and contractors

If a third party has access to PII systems or onsite facilities:

• Contract clause: printing of PII restricted; must follow your procedures; return or destroy on request.
• Access controls: third-party accounts should not be in print-approved groups by default.
• Offboarding checklist: verify no retained hardcopy.

Step 8: Training that matches the workflow

Training should be short and specific:

• “Do not print PII unless you have approval.”
• “Use secure release printers only.”
• “Shred immediately unless retention is required.”
• “Report unattended printouts as a security incident.”

Required evidence and artifacts to retain

Keep evidence that maps directly to “restricted” and “controlled”:

• Policy/standard for restriction of PII hardcopy creation.
• System configurations showing print restrictions (endpoint policies, VDI policies, printer allowlists).
• Printer configuration evidence (secure release enabled, managed device list, physical location list).
• Exception register with approvals, business justifications, scope (who/what/where), and review outcomes.
• Access control records (group membership for print-approved users; join/leave dates).
• Print logs from managed printers (retention per your internal log retention rules).
• Training records for teams authorized to print.
• Disposal process evidence (vendor certificates if used; internal shred-bin chain-of-custody procedures if applicable).
• Audit trail of periodic reviews (e.g., review of who still needs printing privileges).

Common exam/audit questions and hangups

Expect these questions and prepare crisp answers:

1. “Show me how printing of PII is restricted.” They will ask for both policy and technical enforcement.
2. “Who can print PII today, and why?” Have a current list and the approval basis.
3. “Can staff print to home printers?” If yes, you need compensating controls and strong justification; most teams block it.
4. “How do you prevent documents sitting on the printer?” Secure release is the clean answer; otherwise show physical controls and monitoring.
5. “What happens to printed PII after use?” Walk through storage and shredding, then show records.

Hangup to avoid: claiming “restricted” while allowing broad printing with only a clean desk policy.

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails in audits	Fix
Policy says “restrict,” but everyone can print	No evidence of enforcement	Implement RBAC + printer allowlisting
Relying on “don’t print” training only	Training is not a control by itself	Add technical restrictions and approvals
Exceptions have no owner or review	Exceptions become permanent	Assign approver and periodic review trigger
Printing allowed to unmanaged devices	No logging, no secure release, physical risk	Require managed printers and authenticated release
Disposal is informal	High breach risk if found in trash	Document shredding/destruction process and track it

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement. Operationally, the risk is straightforward: printed PII is easy to misplace, copy, photograph, or discard improperly. In an investigation, you may have limited ability to prove what was printed and where it went unless you control printers, approvals, and disposal.

A practical execution plan (30/60/90)

First 30 days (Immediate containment)

• Publish the “print-by-exception” standard for PII hardcopy creation aligned to ISO/IEC 27018 Annex A.11.2. ¹
• Identify top systems that display PII and map where printing occurs.
• Freeze new printing access: require approvals for any new print capability.
• Create an exception register and assign an owner (usually Security/GRC with IT).

Next 60 days (Control rollout)

• Implement managed printer allowlisting and disable printing to unmanaged printers for corporate endpoints where feasible.
• Turn on secure release for printers used by print-approved staff.
• Configure role-based print permissions for the top PII systems (or via endpoint policy if app controls are limited).
• Publish handling and disposal procedures; place locked shred bins where printing is allowed.

By 90 days (Audit-ready operations)

• Run the first access review for print-approved users and close unneeded access.
• Start routine log review for print activity with a defined escalation path.
• Extend restrictions to third parties: contract language, onboarding controls, and offboarding checks.
• Test the process with a tabletop: “PII printout found unattended” and document outcomes.

Where Daydream fits

Daydream can help you operationalize this requirement by keeping the control narrative, exception register, and evidence checklist in one place so audits don’t turn into a scavenger hunt. The goal is simple: one source of truth for “who can print, why they can print, and what controls are in place.”

Frequently Asked Questions

Does “restrict hardcopy creation” mean printing PII is completely forbidden?

No. It means printing must be controlled and limited. You can allow printing for defined business needs, but you need approvals, technical enforcement, and secure handling. ¹

What counts as hardcopy material displaying PII?

Any printed output that shows personal data, including reports, case notes, screenshots, exports, and PDFs printed from PII systems. Treat “displaying PII” broadly so users can’t bypass the intent of the control. ¹

If we can’t technically block printing in an application, can we still comply?

Yes, but you need compensating controls such as endpoint print restrictions, managed printer allowlisting, secure release, and an approval-based process for who may print. Document the gap and the controls that restrict printing in practice. ¹

Do we need to log every print job that might contain PII?

The standard requires restriction; logging supports proof and investigations. If you allow printing, you should capture enough logging to attribute jobs to a user and printer, and review it based on defined triggers. ¹

How do we handle remote workers who print at home?

Treat home printing as a high-risk exception. If you allow it, require explicit approval, defined storage and shredding expectations, and a documented justification tied to business need; many organizations prohibit it to keep enforcement clean. ¹

What should we show an auditor as proof that printing is “restricted”?

Provide the policy standard, the list of print-approved users and approvals, technical configuration evidence (endpoint or printer controls), and records showing secure disposal. The theme is consistent traceability from permission to print through destruction. ¹

Footnotes

1. ISO/IEC 27018:2019 Information technology — Security techniques — Code of practice for protection of personally identifiable information (PII) in public clouds acting as PII processors