TSC-P4.3 Guidance

TSC-P4.3 requires you to securely dispose of personal information across its full lifecycle, including production systems, backups, logs, endpoints, and physical media. Operationalizing the tsc-p4.3 guidance requirement means defining disposal triggers, approved methods (delete, sanitize, shred, destroy), assigning owners, and retaining evidence that disposal occurred and is periodically checked ¹.

Key takeaways:

• Scope disposal beyond databases: include backups, logs, exports, devices, and paper.
• Make disposal event-driven: tie it to retention schedules, contract end, and data subject requests where applicable.
• Keep audit-ready proof: tickets, certificates of destruction, system logs, and review records ¹.

Secure disposal is one of the fastest ways to fail the Privacy criteria in a SOC 2 because it touches systems you don’t “own” day-to-day: backup platforms, SIEM retention, customer support tooling, employee endpoints, and third-party subprocessors. TSC-P4.3 is short, but auditors expect a complete operational story: what “personal information” means in your environment, where it lives, how long you keep it, what triggers disposal, how disposal is executed, and how you prove it happened ¹.

For a CCO or GRC lead, the goal is repeatability. You need a policy that is specific enough for engineering and IT to follow, a disposal standard that matches your technology stack, and a set of artifacts that can be sampled during the audit period. This page gives requirement-level implementation guidance you can hand to system owners: a step-by-step build plan, evidence checklists, and the audit questions that typically expose gaps. It also calls out common failure modes, like forgetting backups or relying on a “we delete on request” narrative with no records.

Regulatory text

Excerpt (TSC-P4.3): “The entity securely disposes of personal information” ¹.

What the operator must do:
You must implement defined, repeatable disposal processes that render personal information irretrievable when it is no longer needed or when a disposal trigger occurs. “Securely disposes” implies method-appropriate destruction (logical or physical) plus governance: documented procedures, execution records, and periodic checks that the process works ¹.

Plain-English interpretation (what auditors look for)

Auditors typically test three things under the tsc-p4.3 guidance requirement:

1. Defined rules: You have written requirements for when personal information must be disposed of and acceptable disposal methods by medium ¹.
2. Proof of operation: You can show disposal actually happened during the audit period, not just that you intended it ¹.
3. Control effectiveness: Someone reviews, monitors, or tests disposal controls so failures (missed deletions, orphaned backups, lingering exports) get caught and fixed ¹.

Who it applies to (entity and operational context)

Entities: Any organization undergoing a SOC 2 audit that includes the Privacy category and therefore the Trust Services Criteria privacy requirements ¹.

Operational scope (where disposal must work):

• Application/data platforms: production databases, data warehouses, analytics platforms, feature stores.
• Unstructured repositories: object storage buckets, file shares, collaboration tools.
• Operational tooling: CRM, ticketing, customer support, chat tools, call recordings.
• Security/IT telemetry: SIEM, endpoint logs, access logs that may contain identifiers.
• Backups and DR: snapshots, backup vaults, offsite replication, archived images.
• Endpoints and physical: laptops, removable media, printed forms, shipping labels.
• Third parties: subprocessors that store or process your personal information.

If a system can hold personal information, it needs a disposal path you can evidence.

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

Step 1: Define “personal information” for disposal scope

Create a short internal definition aligned to your privacy notice and data inventory. Then map it to concrete fields and artifacts (names, emails, device IDs, IP addresses where treated as personal information in your program, recordings, scanned IDs). Keep the mapping in your data inventory so system owners can’t claim ambiguity.

Deliverable: Data classification note + data inventory fields tagged “PI.”

Step 2: Identify disposal triggers (the “when”)

Build a trigger matrix and get it approved by Legal/Privacy and Security:

• Retention expiry: data exceeds approved retention period.
• Contract end: customer termination, trial expiry, or account closure.
• Purpose complete: data collected for a one-time purpose (e.g., identity verification) is no longer needed.
• Security events: media suspected compromised may require special handling (documented exception path).
• Third-party offboarding: subprocessor termination requires deletion/return confirmation.

Practical tip: Tie triggers to systems of record (billing system, IAM deprovisioning, contract management) so disposal isn’t dependent on someone remembering.

Step 3: Standardize approved disposal methods (the “how”)

Create a disposal standard by medium:

• Logical deletion: hard delete vs. cryptographic erasure (key destruction), with safeguards against restoring deleted rows from replicas.
• Backups: expiration and secure deletion; define acceptable lag between production deletion and backup aging-off, then document it as a risk acceptance if it exists.
• Logs: retention configuration, index lifecycle policies, and deletion workflows for exceptional requests.
• Physical media: certified destruction, secure shredding, or vendor-managed destruction with certificates.

Deliverable: “Secure Disposal Standard” with methods and owners per medium ¹.

Step 4: Assign ownership and embed into workflows

For each system that stores personal information, assign:

• Control owner: accountable for disposal working.
• Operator: team that executes disposal jobs or vendor offboarding.
• Approver: reviews exceptions (e.g., legal hold).

Embed tasks into existing systems:

• Ticket templates for “Customer Offboarding Data Deletion”
• Change requests for retention policy changes
• Third-party offboarding checklist item: “Delete/return PI + confirmation”

Step 5: Implement monitoring, review, and periodic assessment

Auditors expect you to detect drift:

• Monitoring: alerts for retention policy failures (backup job failures, lifecycle rules disabled).
• Review: periodic review of retention configurations and deletion job success/failure.
• Assessment: sample-based validation that deleted records are not recoverable through normal access paths ¹.

This aligns to the recommended control themes: monitoring and review, audit trail, and periodic assessments ¹.

Step 6: Build evidence collection into the process

If your team executes deletion but doesn’t retain proof, you will scramble during the audit. Configure evidence capture as part of normal work:

• Require a ticket ID for deletion runs.
• Store certificates of destruction in a controlled repository.
• Export system logs that show lifecycle policies applied and deletion completed.

Where Daydream fits naturally: Daydream can act as the system-of-record for disposal controls and evidence requests, linking your inventory entries (systems holding PI) to the exact tickets, logs, and third-party confirmations auditors sample. That reduces “evidence scavenger hunts” across teams.

Required evidence and artifacts to retain

Keep artifacts that show design, operation, and review ¹:

Design evidence

• Secure Disposal Policy / Standard (approved, versioned)
• Data retention schedule mapped to system inventory
• Roles/responsibilities (RACI) for disposal execution and exceptions
• Third-party contract clauses or addenda covering deletion/return of PI (where applicable)

Operating evidence (auditor sample-friendly)

• Deletion tickets with approvals and completion notes
• Job run logs (batch deletions, lifecycle policies, backup expiration)
• Screenshots/exports of retention configurations (dated)
• Certificates of destruction (physical media, disposal vendor)
• Third-party offboarding confirmations or attestation emails

Review/testing evidence

• Periodic review meeting notes or checklist sign-offs
• Sample test results (what you tested, what you found, remediation)
• Exception register (legal holds, unresolved deletions, compensating controls)

Common exam/audit questions and hangups

Auditors often ask:

• “Show the inventory of systems storing personal information and the disposal method for each” ¹.
• “Provide a sample of deletion events during the audit period and evidence they completed” ¹.
• “How do you handle backups and replicas when a record is deleted?”
• “How do you ensure third parties delete data after termination?”
• “What’s your process for exceptions such as legal hold?”

Hangup areas:

• Backups and log retention get overlooked or treated as “out of scope.”
• Deletions are performed ad hoc with no audit trail.
• Policies exist but don’t specify methods by medium, making them non-testable.

Frequent implementation mistakes and how to avoid them

1. Mistake: “Delete in app” but backups keep the data indefinitely.
   Fix: Document backup retention and aging-off; implement lifecycle rules; keep evidence of configuration and periodic review.

2. Mistake: Disposal depends on tribal knowledge.
   Fix: Codify triggers and workflows; require tickets; assign owners per system.

3. Mistake: No evidence that deletion is secure (irretrievable).
   Fix: Define what “secure” means for each storage type; keep logs, vendor certificates, and validation samples ¹.

4. Mistake: Third-party offboarding has no deletion confirmation.
   Fix: Add offboarding checklist steps and require written confirmation, plus contract language where feasible.

Enforcement context and risk implications

SOC 2 is an audit framework rather than a regulatory enforcement regime, so this requirement is usually enforced through audit findings and customer trust impacts rather than government penalties ¹. Operational risk is still real: weak disposal increases exposure in incidents, eDiscovery, and customer disputes, and it can complicate privacy commitments you make in contracts and public notices.

A practical 30/60/90-day execution plan

Days 1–30: Get to a defensible design

• Confirm audit scope includes Privacy and TSC-P4.3 ¹.
• Build/refresh system inventory entries that store PI; tag primary repositories, backups, logs, endpoints.
• Draft Secure Disposal Standard: triggers, methods by medium, and RACI.
• Create evidence plan: what logs, tickets, and confirmations you will retain.

Exit criteria: Approved disposal standard + inventory coverage for in-scope systems.

Days 31–60: Implement workflows and start producing evidence

• Implement or tighten retention configurations (logs, backups, object storage lifecycle).
• Add deletion/offboarding ticket templates and required fields (system, data type, method, approver).
• Stand up third-party offboarding step: “PI deleted/returned” with stored confirmation.
• Begin a disposal register (simple spreadsheet is fine) to track events and evidence links.

Exit criteria: Disposal actions generate consistent tickets/logs; at least a few real examples exist for sampling.

Days 61–90: Validate and operationalize monitoring/review

• Run a sample-based validation: pick systems, verify deletion cannot be accessed through normal pathways.
• Establish periodic review cadence for retention configs and deletion job health (documented).
• Close gaps found in testing; update standard and runbooks to match reality.
• Prepare an “auditor binder” folder structure: policy, inventory, sample evidence, reviews.

Exit criteria: You can answer “show me” requests quickly with dated artifacts ¹.

Frequently Asked Questions

Does TSC-P4.3 require immediate deletion everywhere, including backups?

TSC-P4.3 requires secure disposal, but implementation typically uses defined retention and aging-off for backups plus documented exceptions ¹. Your job is to define the approach, implement it consistently, and retain evidence.

What counts as “secure disposal” for cloud storage?

Secure disposal means you follow approved deletion/sanitization methods appropriate to the storage medium and access model, and you can prove the action occurred ¹. In practice, that often includes lifecycle policy configuration evidence and deletion job logs.

How do I prove deletion for SaaS third parties we don’t control?

Require written confirmation during offboarding and retain it with the offboarding ticket, plus contract language where feasible. Auditors mainly test that you have a defined process and kept evidence for sampled third parties ¹.

Can we rely on a policy alone if we rarely delete customer data?

No. Auditors expect evidence of operation during the audit period, which can include retention configuration outputs, deletion job logs, or third-party confirmations ¹. If deletion events are rare, plan a controlled test event and retain the artifacts.

Who should own this control: Security, Privacy, or Engineering?

Treat it as shared accountability: GRC/Privacy sets requirements and evidence needs; system owners (Engineering/IT/Data) execute deletion and retention configs. Assign a named control owner who can coordinate sampling and remediation ¹.

What’s the fastest way to get audit-ready evidence without disrupting teams?

Standardize ticket templates and require links to system logs/config exports as completion criteria. A central tool like Daydream can track control owners, map systems to disposal methods, and collect artifacts so evidence doesn’t live in personal folders.

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 Trust Services Criteria 2017