ISO 27001:2022 Annex A 8.10 – Information Deletion Explained

Information that is no longer needed is not harmless.
It is unmanaged risk waiting to be exposed.

Annex A 8.10 exists to ensure organisations delete information securely when it is no longer required, preventing unauthorised disclosure, recovery, or misuse.

This control is about ending the data lifecycle deliberately, not leaving remnants behind.

ISO 27001

Quick Guide: Annex A 8.10 at a Glance

Annex A 8.10 of ISO 27001:2022 focuses on secure information deletion.

At a practical level, this means:

  • Deleting information when it is no longer required
  • Ensuring deleted information cannot be recovered
  • Applying deletion methods appropriate to the media and risk
  • Recording and verifying deletion activities
  • Managing deletion performed by third parties

This is a new control in ISO 27001:2022. It reflects the reality that data persistence is now a primary security and privacy risk.

In-Depth Guide to Annex A 8.10

What Is Annex A 8.10 and Why Does It Matter?

Modern systems retain information by default:

  • Backups persist long after use
  • Temporary files and caches accumulate
  • Cloud platforms replicate data automatically
  • Old devices retain recoverable information

If information is not deleted securely:

  • Sensitive data may be exposed
  • Legal and regulatory obligations may be breached
  • Disposal of systems may result in disclosure
  • Incidents may occur long after data was “finished with”

Annex A 8.10 ensures organisations actively remove information they no longer need, rather than assuming deletion happens automatically or safely.

How to Implement Annex A 8.10 Effectively

A pragmatic approach to Annex A 8.10 typically includes the following elements.

1. Define When Information Should Be Deleted

Organisations should define:

  • Retention periods for different types of information
  • Triggers for deletion (end of contract, system decommissioning, legal expiry)

Deletion should be deliberate and aligned with:

  • Legal and regulatory requirements
  • Business needs
  • Contractual obligations

Deletion too early creates risk.
Deletion too late creates exposure.

2. Identify Where Information Exists

Effective deletion requires knowing where data is stored.

This may include:

  • Production systems
  • Backups and archives
  • Temporary files and caches
  • End-user devices
  • Removable and portable media
  • Cloud platforms and third-party services

Information often exists in more places than expected.

3. Select Deletion Methods Appropriate to Risk

Deletion methods should reflect:

  • Information sensitivity
  • Storage media type
  • Likelihood of recovery

Methods may include:

  • Logical deletion
  • Secure overwriting
  • Cryptographic erasure
  • Physical destruction (see Annex A 7.14)

Simple deletion is rarely sufficient for sensitive information.

4. Ensure Deletion Is Irreversible Where Required

Annex A 8.10 expects organisations to ensure information:

  • Cannot be reconstructed
  • Cannot be recovered using reasonable means

The level of irreversibility should be proportionate to the information risk.

5. Include Temporary and Residual Information

Deletion should not focus only on primary records.

Organisations should consider:

  • Cached data
  • Temporary files
  • Replicated copies
  • Test or development environments

Residual data is a common source of exposure.

6. Record and Verify Deletion Activities

Where risk justifies it, organisations should:

  • Record what was deleted
  • Record when deletion occurred
  • Record who authorised or performed deletion

Records provide:

  • Evidence of compliance
  • Auditability
  • Confidence that deletion actually occurred

Assumed deletion is not defensible deletion.

7. Control and Assure Third-Party Deletion

Where deletion is performed by suppliers or service providers, organisations should:

  • Define deletion requirements clearly
  • Require evidence of deletion
  • Include deletion obligations contractually

This is particularly relevant for:

  • Cloud service providers
  • Managed service providers
  • Specialist data destruction vendors

Outsourced deletion remains organisational risk.

8. Address Deletion During System Decommissioning

Annex A 8.10 strongly supports secure deletion when:

  • Systems are retired
  • Infrastructure is replaced
  • Services are migrated

Decommissioning is a high-risk moment for data exposure.

9. Align Information Deletion With Disposal Controls

Information deletion should align with:

Deletion and disposal are linked — but not the same.

In-Depth Guide to Annex A 5.1

What is Annex A 5.1 and Why Does It Matter?

  • What the organisation values
  • How security decisions are approached
  • Where accountability sits
  • Aligns security with business objectives
  • Supports proportionate, risk-based decisions
  • Provides a reference point during incidents and disputes
  • Creates consistency without bureaucracy

How to Implement Annex A 5.1 Effectively

1. Define a Comprehensive Information Security Policy
  • Scope: What the policy applies to (systems, data, people).
  • Objectives: Why security is important for the business.
  • Roles & Responsibilities: Who is accountable for security.
  • Key Principles: Risk management, access control, and data protection.
2. Secure Senior Management Approval
  • Review and approve policies.
  • Ensure resources are allocated for implementation.
  • Lead by example in enforcing security policies.
3. Communicate and Train Employees
  • Include security policies in onboarding and ongoing training.
  • Ensure policies are easily accessible to all employees.
  • Encourage acknowledgment and acceptance of security responsibilities.
4. Regular Review & Continuous Improvement
  • Set a schedule for periodic policy reviews (at least annually).
  • Update policies based on business changes, new threats, or regulatory updates.
  • Conduct audits to ensure compliance and effectiveness.
5. Integrate Policies into the ISMS
  • Use it to develop more detailed security procedures.
  • Ensure policies align with other Annex A controls and broader risk management practices.
Key Differences: ISO 27001:2013 vs ISO 27001:2022
AspectISO 27001:2013ISO 27001:2022
Control StructureTwo separate controls: 5.1.1 & 5.1.2Merged into one control (5.1)
Implementation GuidanceLess prescriptiveMore detailed guidance for policy creation and alignment
Awareness & TrainingNot explicitly mentionedExplicitly requires policies to be part of training programmes
Attributes TableNot includedew attributes table for mapping policies to industry terms
Common Challenges & How to Overcome Them
  • Challenge: Employees don’t follow security policies.
  • Solution: Make policies practical and relevant to daily work. Use real-world examples in training.
  • Challenge: Policies are outdated or too generic.
  • Solution: Schedule annual reviews and update policies based on real threats and business changes.
  • Challenge: Policies are written in technical jargon.
  • Solution: Use plain language that all employees can understand.
  • Challenge: Lack of leadership buy-in.
  • Solution: Show how weak security affects business objectives—costs of breaches, loss of client trust, and legal penalties.
Final Recommendations
  • Make security policies living documents—review, refine, and update regularly.
  • Use policy training and awareness to create a security-conscious workforce.
  • Ensure policies are accessible, relevant, and easy to understand.
  • Keep policies aligned with business strategy and regulatory requirements.
  • Engage leadership in driving security culture from the top down.

Practical Considerations

Annex A 8.10 does not require:

  • Immediate deletion of all historical data
  • Complex tooling by default
  • Elimination of all data retention

It does require organisations to:

  • Delete information deliberately
  • Prevent recoverable remnants
  • Be able to demonstrate deletion occurred

Data that “might be useful one day” is often the data that causes incidents.

Common Challenges and How to Overcome Them

  • Assuming deletion happens automatically
  • Define and enforce deletion processes
  • Ignoring backups and replicas
  • Include all storage locations in scope
  • No evidence of deletion
  • Record and verify deletion activities
  • Relying on suppliers without assurance
  • Require evidence and contractual commitments

Most data exposure comes from old data, not active systems.

In-Depth Guide to Annex A 5.1

What is Annex A 5.1 and Why Does It Matter?

  • What the organisation values
  • How security decisions are approached
  • Where accountability sits
  • Aligns security with business objectives
  • Supports proportionate, risk-based decisions
  • Provides a reference point during incidents and disputes
  • Creates consistency without bureaucracy

How to Implement Annex A 5.1 Effectively

1. Define a Comprehensive Information Security Policy
  • Scope: What the policy applies to (systems, data, people).
  • Objectives: Why security is important for the business.
  • Roles & Responsibilities: Who is accountable for security.
  • Key Principles: Risk management, access control, and data protection.
2. Secure Senior Management Approval
  • Review and approve policies.
  • Ensure resources are allocated for implementation.
  • Lead by example in enforcing security policies.
3. Communicate and Train Employees
  • Include security policies in onboarding and ongoing training.
  • Ensure policies are easily accessible to all employees.
  • Encourage acknowledgment and acceptance of security responsibilities.
4. Regular Review & Continuous Improvement
  • Set a schedule for periodic policy reviews (at least annually).
  • Update policies based on business changes, new threats, or regulatory updates.
  • Conduct audits to ensure compliance and effectiveness.
5. Integrate Policies into the ISMS
  • Use it to develop more detailed security procedures.
  • Ensure policies align with other Annex A controls and broader risk management practices.
Key Differences: ISO 27001:2013 vs ISO 27001:2022
AspectISO 27001:2013ISO 27001:2022
Control StructureTwo separate controls: 5.1.1 & 5.1.2Merged into one control (5.1)
Implementation GuidanceLess prescriptiveMore detailed guidance for policy creation and alignment
Awareness & TrainingNot explicitly mentionedExplicitly requires policies to be part of training programmes
Attributes TableNot includedew attributes table for mapping policies to industry terms
Common Challenges & How to Overcome Them
  • Challenge: Employees don’t follow security policies.
  • Solution: Make policies practical and relevant to daily work. Use real-world examples in training.
  • Challenge: Policies are outdated or too generic.
  • Solution: Schedule annual reviews and update policies based on real threats and business changes.
  • Challenge: Policies are written in technical jargon.
  • Solution: Use plain language that all employees can understand.
  • Challenge: Lack of leadership buy-in.
  • Solution: Show how weak security affects business objectives—costs of breaches, loss of client trust, and legal penalties.
Final Recommendations
  • Make security policies living documents—review, refine, and update regularly.
  • Use policy training and awareness to create a security-conscious workforce.
  • Ensure policies are accessible, relevant, and easy to understand.
  • Keep policies aligned with business strategy and regulatory requirements.
  • Engage leadership in driving security culture from the top down.

Final Recommendations

Annex A 8.10 is about reducing risk by removing unnecessary information.

When information deletion is managed effectively:

  • Exposure is reduced
  • Regulatory risk decreases
  • Disposal does not equal disclosure
  • Data lifecycle control becomes credible

Information security is not just about protection.
It is also about knowing when to let data go.

Annex A 8.10 ensures organisations do exactly that — securely and deliberately.

In-Depth Guide to Annex A 5.1

What is Annex A 5.1 and Why Does It Matter?

  • What the organisation values
  • How security decisions are approached
  • Where accountability sits
  • Aligns security with business objectives
  • Supports proportionate, risk-based decisions
  • Provides a reference point during incidents and disputes
  • Creates consistency without bureaucracy

How to Implement Annex A 5.1 Effectively

1. Define a Comprehensive Information Security Policy
  • Scope: What the policy applies to (systems, data, people).
  • Objectives: Why security is important for the business.
  • Roles & Responsibilities: Who is accountable for security.
  • Key Principles: Risk management, access control, and data protection.
2. Secure Senior Management Approval
  • Review and approve policies.
  • Ensure resources are allocated for implementation.
  • Lead by example in enforcing security policies.
3. Communicate and Train Employees
  • Include security policies in onboarding and ongoing training.
  • Ensure policies are easily accessible to all employees.
  • Encourage acknowledgment and acceptance of security responsibilities.
4. Regular Review & Continuous Improvement
  • Set a schedule for periodic policy reviews (at least annually).
  • Update policies based on business changes, new threats, or regulatory updates.
  • Conduct audits to ensure compliance and effectiveness.
5. Integrate Policies into the ISMS
  • Use it to develop more detailed security procedures.
  • Ensure policies align with other Annex A controls and broader risk management practices.
Key Differences: ISO 27001:2013 vs ISO 27001:2022
AspectISO 27001:2013ISO 27001:2022
Control StructureTwo separate controls: 5.1.1 & 5.1.2Merged into one control (5.1)
Implementation GuidanceLess prescriptiveMore detailed guidance for policy creation and alignment
Awareness & TrainingNot explicitly mentionedExplicitly requires policies to be part of training programmes
Attributes TableNot includedew attributes table for mapping policies to industry terms
Common Challenges & How to Overcome Them
  • Challenge: Employees don’t follow security policies.
  • Solution: Make policies practical and relevant to daily work. Use real-world examples in training.
  • Challenge: Policies are outdated or too generic.
  • Solution: Schedule annual reviews and update policies based on real threats and business changes.
  • Challenge: Policies are written in technical jargon.
  • Solution: Use plain language that all employees can understand.
  • Challenge: Lack of leadership buy-in.
  • Solution: Show how weak security affects business objectives—costs of breaches, loss of client trust, and legal penalties.
Final Recommendations
  • Make security policies living documents—review, refine, and update regularly.
  • Use policy training and awareness to create a security-conscious workforce.
  • Ensure policies are accessible, relevant, and easy to understand.
  • Keep policies aligned with business strategy and regulatory requirements.
  • Engage leadership in driving security culture from the top down.

The Annex Control Table

ISO 27001:2022 Organisational Controls
ISO 27001:2022 Technological Controls