Downstream Data Destruction Vendor Checklist Vendor Name: Other Business Names: Address: This checklist is designed for the evaluation of potential vendors for data destruction under R2:2013 Provision 8. This checklist covers the requirements of outsourcing data destruction. Vendors may include those contracted for data destruction specifically, where the R2:2013 recycler does not have the capabilities internally. It also includes vendors who are sent equipment for refurbishment or recycling which have not been sanitized by the R2:2013 recycler and still contain data that must be controlled and destroyed. Document the types of media sent to the downstream vendor for data destruction. Describe the processing techniques by the downstream vendor for each type of media. Remove or change media types specific to each downstream vendor. Media Processing Technique Hard Drive Solid State Drive Optical disk Floppy Disk Data Tape Video Tap SD Cards ROM 1 Revision Date: 2015 © SERI Inc – All Rights Reserved Downstream Data Destruction Vendor Checklist Data Destruction Requirements Prov. 8(a) 8(a) 8(b) 8(c) 8(c) 8(c) 8(d) 8(d) 8(e) 8(e) 8(e) Requirement Has the refurbisher incorporated the applicable requirements of NIST 800-88 or other generally-accepted standard into its data destruction procedures? Are instructions for the identification of media containing data and requiring sanitization included in the refurbishers EHSMS? [NIST 800-88 Section 4.2] Does the refurbisher adhere to the incorporated data destruction standards for all data bearing media? Does the refurbisher document its data destruction procedures and include this documentation as part of its EHSMS? Do employees involved in data destruction receive appropriate training in data destruction processing? Do employees involved in data destruction receive repeat training in data destruction processing on a regular basis? Are employees involved in data destruction pre-qualified through an evaluation of competency prior to processing media for data destruction? Are data destruction validation requirements and processes documented in the data destruction procedures as part of the EHSMS? Are data destruction processes reviewed and validated by an independent party on a periodic basis as defined in the data destruction procedures? Are quality controls for data destruction documented? Are quality controls for data destruction effectively implemented and used? Are quality controls for data destruction regularly monitored internally for effectiveness? Verification 2 Revision Date: 2015 © SERI Inc – All Rights Reserved Downstream Data Destruction Vendor Checklist Prov. 8(f) 8(f) 8(f) 8(f) 8(f) 8(f) 8(g) 8(h)(1) 8(h)(1) 8(h)(2) 8(h)(3) Requirement Has the level of sensitivity of data on media received at the facility been determined? Are security controls for media containing data documented? [ Are documented security controls for media containing data implemented? Are security controls and procedures maintained and updated as changes occur in facility, personnel, or media sensitivity? Are implemented security controls appropriate for the most sensitive classification of media accepted at the facility? Do security controls consider physical security, monitoring, chainof-custody, and personnel qualifications? Are adequate records of data destruction maintained by the recycler and each downstream vendor conducting data destruction? If data destruction is handled by a downstream vendor to the refurbisher, does the refurbisher maintain responsibility for data destruction? If data destruction is handled by a downstream vendor, does the refurbisher ensure appropriate security, controls, and processing techniques continue to conform to Provision 8 through audits or other similarly effective means? If data destruction is handled by a downstream vendor, are media or devices containing media with data tracked and secured during transportation, storage, and processing? If data destruction is handled by a downstream vendor, does each downstream vendor adhere to the requirements of Provision 8? Verification The above information applies to the minimum requirements of R2:2013 Provision 8 for outsourcing data destruction. Additional evaluation is recommended. Onsite audits are encouraged. 3 Revision Date: 2015 © SERI Inc – All Rights Reserved Downstream Data Destruction Vendor Checklist Year 1 Evaluator: Attached Evidence: Comments: Status: ☐ Approved ☐ Suspended Date Completed: Year 2 Evaluator: Attached Evidence: Comments: Status: ☐ Approved ☐ Suspended Date Completed: Year 3 Evaluator: Attached Evidence: Comments: Status: ☐ Approved ☐ Suspended Date Completed: 4 Revision Date: 2015 © SERI Inc – All Rights Reserved