The entity securely disposes of personal information

Secure disposal is one of the fastest ways to fail a privacy control set during a SOC 2 readiness effort because teams confuse “deleted” with “disposed.” For SOC 2 Privacy, disposal is an operational control, not a policy statement. You need a process that tells staff and systems exactly when personal information must be destroyed, what method is acceptable for each medium, how exceptions are handled (legal holds, customer disputes, security investigations), and how you prove it happened.

This requirement becomes real in everyday workflows: customer offboarding, employee termination, expired trial accounts, deleted tickets containing identity documents, old exports in shared drives, database backups retained too long, or “temporary” analytics datasets that become permanent. The disposal control also crosses boundaries: IT owns many technical methods, Legal may set retention and litigation hold rules, Security may set sanitization standards, and Product/Engineering controls data architecture that determines whether disposal is even feasible.

This page gives you requirement-level implementation guidance to get compliant quickly, generate defensible evidence, and avoid the common audit hangups that cause SOC 2 Privacy findings.

Regulatory text

Requirement: “The entity securely disposes of personal information.” ¹

Operator interpretation (plain English)

You must ensure personal information is destroyed or rendered unrecoverable when it is no longer needed for the stated purpose, contractual obligations, or legal/regulatory retention. “Securely disposes” means your method matches the storage medium and risk, and it prevents reconstruction by ordinary means (and, for higher-risk data, by forensic means).

What an auditor will expect you to be able to show

• A written disposal/retention design that is specific enough to operate (not just a one-line policy).
• A traceable link from retention rules → disposal triggers → disposal actions → evidence.
• Proof that disposal applies everywhere personal information lives, including non-production and third parties.

Who this applies to

Entities and environments in scope

This applies to service organizations seeking alignment to the SOC 2 Trust Services Criteria for Privacy, including organizations processing personal information for customers, employees, contractors, end users, or business contacts. ¹

Operational contexts where this requirement shows up

• Customer lifecycle: account closure, contract termination, deletion requests, expired trials, data migration projects.
• Workforce lifecycle: employee separation, contractor offboarding, HR record archiving and destruction.
• Security operations: disposal of incident exports, malware investigation artifacts, and forensic images after closure.
• Engineering and analytics: dataset refreshes, feature flags storing user attributes, ML training data, debug logs.
• IT asset management: device decommissioning, drive replacement, printer/scanner storage, paper records.
• Third party processing: SaaS tools, call centers, support platforms, marketing tools, cloud providers, shredding vendors.

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

Step 1: Define “personal information” for disposal purposes

Create an internal definition aligned to your privacy notice/customer contracts and your data classification scheme. You need a list of examples that engineers and IT can recognize (names, emails, device IDs, government identifiers, biometrics, precise location, HR files, support attachments). Keep it short and operational.

Artifact: Personal information definition + examples table (owned by Privacy/GRC, reviewed by Legal and Security).

Step 2: Build a data inventory focused on disposal scope

You don’t need a perfect enterprise data map on day one, but you do need a disposal-scoped inventory that answers:

• Where does personal information exist (systems, buckets, shares, endpoints, paper)?
• Who owns each store (system owner)?
• What is the authoritative retention rule?
• How is disposal executed and evidenced?

Include non-production copies explicitly: staging databases, QA snapshots, developer laptops (if allowed), test S3 buckets, synthetic vs real data.

Artifacts: Disposal-scoped data inventory; system owner attestations.

Step 3: Set retention rules that are implementable

Translate retention into concrete rules that systems can enforce. Avoid vague statements like “keep as long as necessary.” Instead, define trigger-based retention such as:

• “Customer account data: retain until contract end + defined business retention period unless legal hold.”
• “Support ticket attachments: delete after case closure + defined period.”
• “Access logs containing user identifiers: retain for security monitoring period.”

You are not required by SOC 2 to pick a specific duration. You are required to have a rule, apply it consistently, and show secure disposal when the rule says “stop retaining.” ¹

Artifacts: Data retention schedule; legal hold standard/procedure; exception register.

Step 4: Define approved disposal methods by medium

Create a disposal standards matrix. Map data location to approved method and evidence.

Practical disposal method matrix (example structure):

• Cloud object storage: delete + lifecycle policy + versioning considerations + secure delete approach appropriate to provider features; evidence from lifecycle configuration and deletion logs.
• Databases: hard-delete or cryptographic erasure (destroy keys) if architecture supports it; evidence from job runs, tickets, and key management logs.
• Backups: ensure retention is bounded; support deletion/expiration; evidence from backup policy and restore-point listings.
• Endpoints: remote wipe or drive encryption with key destruction; evidence from MDM actions and device disposition records.
• Paper: cross-cut shredding or certified destruction service; evidence from certificates of destruction and pickup logs.
• Removable media: sanitize or physically destroy; evidence from asset disposition forms.

Your security team should sign off on the methods as “secure” for your risk level; your IT/Engineering teams must confirm feasibility.

Artifacts: Secure disposal standard; configuration baselines; third party destruction SOP.

Step 5: Implement disposal triggers in workflows (make it hard to skip)

Add disposal triggers to real operational events:

• Offboarding: HR/IT offboarding checklist includes mailbox and drive disposition, device wipe, and account closure steps.
• Customer termination: offboarding runbook includes data export (if required), deletion steps, and confirmation.
• Deletion requests: intake → identity verification → system execution → confirmation; track exceptions (e.g., legal hold).
• System lifecycle: decommissioning checklist includes data archival decisions, secure wipe, and access removal.

Use your ticketing system as the control backbone. Most SOC 2 auditors accept a well-structured ticket trail if it includes the “what/when/who/how” and links to system logs.

Artifacts: Runbooks; ticket templates; approval steps; completed tickets with evidence links.

Step 6: Cover third parties explicitly

If a third party stores or processes your personal information, your disposal control must extend to them contractually and operationally. Minimum expectations:

• Contract terms covering return/deletion at termination and secure disposal.
• A process to trigger third party deletion upon offboarding or deletion requests.
• Evidence of completion (attestation, confirmation, or audit report excerpt if available).

Artifacts: Standard contract clauses; third party offboarding checklist; deletion confirmations.

Step 7: Monitor and prove operation (control performance)

Define how you will detect breakdowns:

• Periodic review of retention configurations (backup retention, lifecycle rules, log retention).
• Sampling of completed deletion/offboarding tickets to confirm evidence quality.
• Exception review (legal holds, failed jobs, systems not yet automated).

This is where many SOC 2 efforts fail: controls exist, but nobody checks whether disposal actually happened across the inventory.

Artifacts: Review logs; sampling worksheet; exception remediation tickets.

Required evidence and artifacts to retain

Keep evidence in a way that a third-party auditor can re-perform or validate the control without relying on tribal knowledge.

Minimum evidence set:

• Secure disposal policy/standard and data retention schedule (approved, versioned).
• Disposal-scoped data inventory with system owners.
• Configuration evidence: lifecycle policies, retention settings, backup policies, log retention settings.
• Execution evidence: tickets, job run logs, deletion reports, key destruction logs (if using cryptographic erasure).
• Physical destruction: certificates of destruction, asset disposition records, MDM wipe confirmations.
• Third party: contractual language and deletion/return confirmations.
• Exception register: legal holds, technical constraints, risk acceptances with dates and owners.

Common exam/audit questions and hangups

Auditor question	What they are testing	What to show
“Where does personal information live?”	Completeness of scope	Inventory with owners, especially backups/logs/non-prod
“How do you dispose of it?”	Method suitability	Disposal standards matrix + technical configs
“Prove it happened for a sample.”	Operating effectiveness	Tickets + logs + timestamps + approver/executor
“What about backups?”	Realistic disposal	Backup retention policy + expiration evidence
“What about third parties?”	Extended responsibility	Offboarding process + confirmation evidence

Frequent implementation mistakes (and how to avoid them)

1. Assuming delete = secure disposal. Deletion in an app UI may not remove database records, indexes, caches, or attachments. Fix: define system-level deletion semantics and test them.
2. Ignoring non-production. Engineers copy production data into test environments “temporarily.” Fix: ban real data in non-prod or enforce strict controls and disposal automation.
3. Backups kept indefinitely. Fix: set bounded backup retention, document restore needs, and ensure retention aligns to your stated rules.
4. No evidence trail. Teams perform deletions but can’t prove it later. Fix: require tickets with linked logs/screenshots/config exports.
5. Third party offboarding is ad hoc. Fix: create a trigger list tied to procurement and system inventory; record deletion confirmations.
6. Legal hold is informal. Fix: implement a written legal hold process with named authority and documented release.

Enforcement context and risk implications

No public enforcement cases were provided for this requirement in the source catalog, so this page does not cite specific actions. Practically, failure modes are consistent across privacy programs: over-retention increases breach impact, complicates incident response, and creates tension between privacy commitments and operational reality. For SOC 2, the near-term risk is a control deficiency because you cannot demonstrate operating effectiveness against the requirement language. ¹

Practical 30/60/90-day execution plan

First 30 days: establish control design and scope

• Assign accountable owners: Privacy/GRC (control owner), Security (method approval), IT/Engineering (implementation).
• Publish a secure disposal standard and retention schedule draft tied to business triggers.
• Build the disposal-scoped inventory for your highest-risk systems first (core product DBs, support platform, HRIS, file storage, backups).
• Implement ticket templates for customer offboarding and deletion requests with required evidence fields.
• Decide approach for non-production (prohibit real data or enforce strict controls).

Days 31–60: implement and collect first operating evidence

• Configure lifecycle/retention in cloud storage, logs, ticket attachments, and backups where feasible.
• Document and test deletion procedures for top systems; capture “proof artifacts” examples.
• Stand up a third party offboarding checklist and add contract clause language for disposal/return.
• Run an internal sample: pick a set of closed accounts/tickets and verify disposal evidence end-to-end. Create remediation tickets for gaps.

Days 61–90: harden, monitor, and make it audit-ready

• Add periodic reviews: retention settings review and ticket sampling review; document results.
• Expand inventory coverage to remaining systems and edge cases (exports, shared drives, email, chat tools).
• Formalize exceptions: legal holds, technical constraints, and approved risk acceptances.
• Package the audit binder: policy/standard, inventory, configs, sample tickets, review records, and third party confirmations.

Where Daydream fits naturally: teams often stall at “prove it happened.” Daydream can centralize the disposal-scoped inventory, map retention/disposal controls to evidence requests, and maintain an audit-ready trail of tickets, configs, and attestations without chasing screenshots across systems.

Frequently Asked Questions

Does “securely disposes” mean we must physically destroy drives?

Not always. Secure disposal depends on the medium and risk; encrypted media with verified key destruction can be appropriate in some architectures. Document the approved methods in your disposal standard and keep evidence that the method was applied. ¹

How do we handle backups if we can’t delete a single user from historical backup sets?

Use bounded backup retention and document that backups are for restoration, not production processing. Ensure backups expire per policy, and document access controls so personal information in backups is not used outside recovery workflows. ¹

Are anonymization or de-identification acceptable forms of disposal?

They can be, if the result is irreversible for your threat model and the data no longer qualifies as personal information under your program definition. Document the technique, where it’s applied, and how you prevent re-linking. ¹

What evidence is strongest for SOC 2 testing?

Auditors typically accept a combination of (1) written standards, (2) system configuration exports, and (3) completed tickets showing who approved/executed disposal and linking to logs that show deletion or destruction actions. ¹

How should we manage legal holds without breaking the disposal requirement?

Treat legal hold as a documented exception with a clear approver, scope, start date, and release event. Keep the exception register and show that disposal resumes when the hold is lifted. ¹

Do third parties need to provide certificates of destruction?

Not always, but you need reasonable evidence they completed deletion or destruction per contract and your request. For SaaS, a written confirmation or administrative record tied to offboarding is often the practical equivalent. ¹

Related compliance topics

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

Footnotes

1. AICPA TSC 2017