ISO 27701, Clause 8.4 – Privacy by Design and Privacy by Default

ISO 27701 clause 8.4 ensures that an organisation’s PII collecting and processing operations limit efforts to the minimum that’s required, in order to achieve a set of identified purposes.

ISO 27701 Clause 8.4.1 – Temporary Files

Purpose of Clause 8.4.1

Organisations need to ensure that temporary files are destroyed within a reasonable amount of time, in accordance with an official retention policy and clear deletion procedures.

Guidance on Clause 8.4.1

A simple way to identify the existence of such files is to perform periodic checks of temporary files across the network.

Organisations should adhere to a so-called garbage collection procedure that deletes temporary files when they’re no longer needed.

ISO 27701 Clause 8.4.2 – Return, Transfer or Disposal of PII

Purpose of Clause 8.4.2

Organisations need to have concrete plans in place that govern how PII can be returned, transferred or disposed of, and make all such policies available to the customer.

Guidance on Clause 8.4.2

There are various scenarios that require the disposal of PII, including (but not limited to):

• Returning any PII to the customer.
• Providing the PII to another organisation.
• Destroying information.
• De-identification.
• Archiving.

Organisations need to provide categorical assurances that any PII which is no longer needed is going to be destroyed in accordance with any prevailing legislation or regional guidelines.

All disposal policies should be available to the customer on demand, and should cover the period of time that organisations have to destroy PII, once a contract has been terminated.