Auditing ISO 27001 Annex A 7.14 Secure Disposal or Re-use of Equipment is the technical verification of data destruction protocols and hardware lifecycle integrity. The Primary Implementation Requirement mandates verified media sanitisation and physical destruction, providing the Business Benefit of eliminating data breach risks from decommissioned or repurposed information assets.
ISO 27001 Annex A 7.14 Secure Disposal or Re-use of Equipment Audit Checklist
This technical verification tool is designed for lead auditors to establish the efficacy of data sanitisation and hardware lifecycle management. Use this checklist to validate compliance with ISO 27001 Annex A 7.14.
1. Equipment Disposal Policy Formalisation Verified
Verification Criteria: A documented policy exists defining the mandatory security requirements for the disposal or re-use of equipment containing storage media.
Required Evidence: Approved Asset Disposal Policy or Data Sanitisation Standard with explicit version control.
Pass/Fail Test: If the organisation cannot produce a formal policy specifying how data must be erased before equipment leaves the premises, mark as Non-Compliant.
2. Media Sanitisation Methodology Alignment Confirmed
Verification Criteria: Data erasure methods are aligned with recognised international standards (e.g. NIST 800-88 or HMG IS5) based on the classification of the data previously held.
Required Evidence: Technical configuration logs of sanitisation software or service level agreements (SLAs) with disposal vendors citing specific standards.
Pass/Fail Test: If the organisation uses standard OS “Format” commands rather than cryptographic erasure or multi-pass overwriting for sensitive assets, mark as Non-Compliant.
3. Data Destruction Certification Presence Validated
Verification Criteria: Every piece of disposed equipment containing media is supported by a unique certificate of destruction or erasure.
Required Evidence: Asset disposal folder containing certificates cross-referenced against the Master Asset Register serial numbers.
Pass/Fail Test: If a sampled asset is marked as ‘Disposed’ in the register but lacks a corresponding destruction certificate, mark as Non-Compliant.
4. Internal Re-use Sanitisation Records Identified
Verification Criteria: Equipment repurposed for a different department or user undergoes a verified data wipe to prevent unauthorised internal data spill.
Required Evidence: IT ticket logs or technician sign-off sheets confirming sanitisation before the asset was re-imaged and re-issued.
Pass/Fail Test: If an asset is transferred between users without a recorded sanitisation step, mark as Non-Compliant.
5. Physical Destruction of Damaged Media Confirmed
Verification Criteria: Storage media that cannot be electronically wiped due to hardware failure is subjected to physical destruction (shredding, crushing, or incineration).
Required Evidence: Photos of crushed media or waste transfer notes from a certified physical destruction provider.
Pass/Fail Test: If faulty hard drives are stored in unsecure “e-waste” bins without being physically rendered unreadable, mark as Non-Compliant.
6. Secure On-site Storage of E-Waste Verified
Verification Criteria: Equipment awaiting disposal or collection is stored in a secure, restricted-access area to prevent opportunistic theft of data.
Required Evidence: Physical sighting of a locked room or secure cage designated for “Assets Awaiting Destruction.”
Pass/Fail Test: If decommissioned laptops or servers are found in an open-access hallway or unlocked basement, mark as Non-Compliant.
7. Vendor Vetting and Environmental Compliance Validated
Verification Criteria: Third-party disposal contractors are vetted for security competency and hold relevant environmental and security certifications.
Required Evidence: Valid ISO 27001 or ADISA (Asset Disposal & Information Security Alliance) certification for the disposal partner.
Pass/Fail Test: If the disposal vendor lacks an active security certification or a formal data processing agreement (DPA), mark as Non-Compliant.
8. Cloud Instance and Virtual Asset Decommissioning Verified
Verification Criteria: Decommissioning of virtual equipment (instances/storage buckets) includes the secure deletion of data and removal of all access keys.
Required Evidence: Cloud provider logs (e.g. AWS CloudTrail) showing resource termination and cryptographic key revocation.
Pass/Fail Test: If a virtual server is terminated but its associated unencrypted snapshots or backups remain active, mark as Non-Compliant.
9. Maintenance of Disposal Chain of Custody Confirmed
Verification Criteria: A documented chain of custody exists for all equipment from the point of decommissioning to the final point of destruction.
Required Evidence: Signed collection manifests showing the number of items and serial numbers transferred to the disposal vendor.
Pass/Fail Test: If the organisation cannot prove exactly which serial numbers were handed over to the courier, mark as Non-Compliant.
10. Management Review of Disposal Trends Recorded
Verification Criteria: Annual reviews of the disposal process are conducted to ensure no assets are “lost” and that the vendor is meeting security obligations.
Required Evidence: Management Review Meeting (MRM) minutes or Audit Reports specifically addressing asset disposal metrics.
Pass/Fail Test: If the organisation has not performed a reconciliation between “Retired” assets and “Destroyed” certificates in the last 12 months, mark as Non-Compliant.
| Control Requirement | The ‘Checkbox Compliance’ Trap | The Reality Check |
|---|---|---|
| Policy Formalisation | Tool identifies an “Asset Policy” PDF exists. | Verify the Technical Standards. Does it cite NIST 800-88 or just say “wipe it”? GRC tools miss the lack of technical rigor. |
| Destruction Certificates | Platform marks “Compliant” because a vendor invoice is uploaded. | Verify Serial Number Granularity. An invoice proves payment; only a certificate proves this specific disk was destroyed. |
| Internal Re-use | GRC tool assumes assets stay with one user forever. | Audit the Helpdesk Tickets. If a laptop moves from ‘Sales’ to ‘Finance’ without a wipe ticket, the tool won’t flag the data leak. |
| E-Waste Storage | SaaS tool records “Locked Room” as a control. | Verify Access Control. GRC tools don’t know that the “locked room” key is kept in an unlocked drawer at reception. |
| Faulty Media | Tool identifies “Encrypted Disk” as a pass. | Check the RMA Process. If a faulty encrypted drive is sent back to the manufacturer without being physically crushed, the control fails. |
| Chain of Custody | Platform logs a task as “Done” when the vendor collects. | Verify the Manifest. Does the signature on the manifest match an authorised staff member? GRC tools ignore the human handover. |
| Sanitisation Logic | Tool assumes a “Factory Reset” is sufficient. | Verify Forensic Persistence. Factory resets often leave data recoverable. Demand proof of cryptographic erase or overwriting. |
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