Reuse and Disposal of Information Assets
Certification criterion
In the process of reusing and disposing of information assets, secure reuse and disposal procedures must be established and implemented so that personal information and important information cannot be recovered or restored.
Key checkpoints
- Are procedures for the secure reuse and disposal of information assets established and implemented?
- When information assets and storage media are reused or disposed of, is personal information and important information processed in a manner that prevents recovery?
- When information assets and storage media are disposed of internally, is the disposal history kept in a management ledger and is evidence of disposal confirmation retained together?
- When information assets and storage media are disposed of through an external company, is the disposal procedure specified in the contract and is it verified whether disposal was carried out completely?
- In the course of maintaining or repairing information systems, PCs, etc., when storage media replacement or recovery occurs, are measures prepared to protect the information within the storage media?
Detailed explanation
Procedures for the secure reuse and disposal of information assets must be established and implemented.
- Information asset reuse procedure: data initialization methods, reuse processes, etc.
- Information asset disposal procedure: disposal methods, disposal processes (approval, etc.), disposal confirmation, recording in a disposal management ledger, etc.
When information assets and storage media are reused or disposed of, personal information and important information must be processed in a manner that prevents recovery.
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When destroying personal information, it must be safely destroyed in accordance with the law so that it cannot be recovered or restored.
※ Methods of destruction that make restoration impossible (examples)
- Complete destruction (incineration, shredding, etc.)
- Deletion using dedicated degaussing equipment (degausser)
- Performing initialization or overwriting so that data cannot be restored
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The term "method that makes restoration impossible" refers to a method of taking measures so that the destroyed personal information cannot be restored at a socially reasonable cost given the current level of technology (Article 10 of the Standard Personal Information Protection Guidelines).
When information assets and storage media are disposed of internally, the disposal history must be kept in a management ledger that includes the following, and evidence of disposal confirmation must be retained together.
- Date of disposal
- Name of the person in charge of disposal and the name of the verifier
- Method of disposal
- Evidence of disposal confirmation (photographs, etc.)
When information assets and storage media are disposed of through an external company, the disposal procedure must be specified in the contract, and it must be verified whether disposal was carried out completely in accordance with that procedure.
- Reflect the disposal procedure, protective measures, and allocation of responsibility, etc., in the contract.
- Verify evidence of implementation, such as photography and on-site inspection, to confirm whether disposal is being carried out in accordance with the disposal procedure reflected in the contract.
In the course of maintaining or repairing information systems, PCs, etc., when storage media replacement or recovery occurs, measures must be prepared to protect the information within the storage media.
- Migrating and destroying data before requesting maintenance
- Data encryption
- Confidentiality pledge at the time of contract
- Complete deletion of data or complete destruction of storage media, etc.
Related laws
- Personal Information Protection Act Article 21 (Destruction of Personal Information)
- Standards for Measures to Ensure the Safety of Personal Information Article 13 (Destruction of Personal Information)
Evidence (examples)
- Information asset disposal and reuse procedures
- Storage media management ledger
- Evidence of disposal of information assets and storage media
- Consignment contracts related to the disposal of information assets and storage media
Nonconformity examples
- A case where the policy and procedures are established to require complete deletion using a data deletion program when reusing a personal information handler's PC, but in practice the PC is reused without complete deletion measures, or is reused after only a basic format, and thus the relevant procedures are not being implemented
- A case where storage media are disposed of through an external company, but the contents regarding secure disposal procedures and protective measures are omitted from the contract, and management/supervision such as verification of disposal implementation evidence and on-site inspection is not carried out
- A case where the system name, rather than the serial number of the disposed HDD, is recorded, or a disposal ledger is not prepared, so that the disposal history and traceable evidence cannot be verified
- A case where collected hard disks slated for disposal are left, without complete deletion, in a place that is not locked