SOC 2 C1.2: Confidentiality - Disposal of Confidential Information

Write a data retention and disposal policy defining retention periods for each category of confidential information. Base these on legal and regulatory requirements (which often mandate minimum retention), contractual obligations, business needs, and the principle that data shouldn't be kept longer than necessary. Document the rationale for each retention period.

Automate data deletion. Configure systems to automatically purge or archive data that's exceeded its retention period. For databases, implement lifecycle management that identifies and removes expired records. For file systems, use automated policies that flag or delete files past their retention date. For email, configure retention policies in the email platform.

Set up secure disposal procedures for electronic media. Match the method to the media type: for hard drives, use NIST SP 800-88 compliant overwriting or physical destruction. For SSDs, use cryptographic erasure or physical destruction. For cloud storage, use provider deletion APIs and verify removal from all replicas and backups. For backup tapes, use degaussing or physical shredding.

Set up secure disposal for physical documents. Provide cross-cut shredders for in-office disposal. Use locked collection bins for bulk document disposal. Engage certified document destruction vendors for large volumes and keep certificates of destruction.

Maintain disposal records. Document what was disposed of, the method used, the date, and who performed or verified the disposal. For third-party media destruction, obtain and retain certificates of destruction. These records are your audit evidence.

Audit data retention compliance periodically. Check that data past its retention period is actually being disposed of, that automated deletion is working, and that no unauthorised copies of confidential information linger in unexpected places like developer workstations, test environments, or personal devices.