3.5·critical·Component: ProtectWhat this control requires
Securely dispose of data as outlined in the enterprise's data management process. Ensure the disposal process and method are commensurate with the data sensitivity.
In plain English
Securely dispose of data as outlined in the enterprise's data management process. In practice, this means you can prove you ensure data management process-level controls on a defined cadence.
Why it matters
The CIS Controls are an industry-vetted, prioritised defence: skipping a safeguard widens the attack surface that the safeguards above and below it assume is closed. Audit frameworks (FedRAMP, PCI DSS, HIPAA) all cite CIS as evidence of due care.
This control is rated critical in the source catalogue. Treat gaps here as production incidents in the risk register, not housekeeping.
What an auditor looks for
A CIS-aligned reviewer wants to see (a) which Implementation Group you are targeting, (b) a documented owner for the safeguard, and (c) a tooling or process artefact (config, scan output, ticket) that proves the safeguard runs on the cadence the control demands.
Within Protect, the assessor will trace your implementation back to the catalogue reference (Control 3.5) and look for objective evidence on the latest two assessment cycles.
How to implement
Policy Management
Docs. Keep each policy in version-controlled Markdown alongside the code that implements it; ship a signed PDF snapshot at each annual review and link the SHA into the SoA.
Operational checklist
- Ensure. Document the trigger, the owner and the cadence.
- Securely. Document the trigger, the owner and the cadence.
- Protect. Document the trigger, the owner and the cadence.
- Scope: data management process, disposal, data sensitivity, enterprise.
Evidence to collect
- Policy Document. A signed and version-controlled policy / standard / procedure document.
Signed policy or standard documents the safeguard. Focus: Securely Dispose of Data.
Common pitfalls
- Policies that no engineer has read; the version in Confluence drifts from the version that's actually being enforced.
How it maps to other frameworks
Computed from shared tags, control component and key-operation subjects — handy when you are reconciling controls across an audit.
- SOC 2 (2017 TSC) P4.3 — Secure Disposal of Personal Information
- HIPAA (45 CFR Part 164) 164.308(a)(1)(ii)(B) — Security Management Process - Risk Management
- BSI C5:2020 HR-02 — Employment terms and conditions
- ISO/IEC 27001:2022 A.5.5 — Contact with authorities
- NIST SP 800-171 Rev. 3 3.13.15 — Session Authenticity
Related controls in CIS Controls v8
- Control 3.1 — Establish and Maintain a Data Management Process
- Control 3.4 — Enforce Data Retention
- Control 7.1 — Establish and Maintain a Vulnerability Management Process
- Control 3.2 — Establish and Maintain a Data Inventory
- Control 11.1 — Establish and Maintain a Data Recovery Process
- Control 3.8 — Document Data Flows
References
- Center for Internet Security — CIS Controls v8
- Catalogue identifier:
Control 3.5
Topics: governance riskpolicy management