ISO/IEC DIS 27555
Clause 5 to 10: The deletion framework

ISO/IEC DIS 27555 9: Requirements for implementation

What does 9 require?

Clause 9 is the largest clause and the one the DIS expands most. It covers organisation wide aspects such as backup, logs, transmission, repair and disposal, individual systems, manual processes, processors, exceptions and individual deletion requests. Clause 9 is where a deletion policy meets the estate. The organisation wide list is a map of the places records escape the live system. Backup keeps a copy after the rule has run. Logs record the deletion itself and can contain the very identifiers that were meant to go. Transmission systems leave copies in queues, mail gateways and partner inboxes. Repair and dismantling can move a disk to a third party. Disposal of components is the end of the line and needs a record. Everyday business life covers the paper, the notebooks, the whiteboards and the desk drawers. The individual system part asks for the same thinking one application at a time, because a central policy that never reaches the application owner does not delete anything. Manual processes matter because a paper file cannot be deleted by a script. The processor part is the contractual route: the controller must be able to show that a processor follows the rules, and the processor must be able to show what it did. The special cases are exception management and further sets of PII, which is the draft's way of saying that a deletion framework must survive the record that does not fit. The individual request route is the operational face of the right to erasure. A request can ask for deletion or for suspension, and the organisation needs a path that reaches every cluster, records the decision and proves the outcome. The DIS gives this clause more space than the earlier edition, and a team updating a policy should treat the expansion as the work plan.

Maintained by Gerard Blokdyk

Other controls in Clause 5 to 10: The deletion framework

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