ISO/IEC 27018 FAQ PII Return And Deletion

Start with the operational decision: define what PII Return And Deletion means in your ISO/IEC 27018 scope, who owns it, and what record proves the decision is current.

In practical terms, the answer is that a processor should return or delete the personal data when the controller instructs it to do so, especially after the service ends, and it should not keep copies unless a law requires retention or another legal exception applies.

The evidence should show the process operating. For this artifact, the strongest record usually includes customer instructions, DPA clauses, subprocessor notices, deletion and return records, disclosure records, access logs, and incident support evidence.

Avoid evidence that only repeats a requirement. A reviewer should be able to see the actual owner, date, system, supplier, AI system, service, incident, risk, or control sample behind the answer.

The person who can fund, operate, and correct the process should own the decision; governance should review consistency and exceptions.

For high-impact changes, approval should include the teams affected by the evidence: security, privacy, resilience, supplier management, AI governance, legal, risk, or business service owners as relevant.

Review it at planned intervals and whenever the underlying scope, service, supplier, control, risk, AI system, personal data flow, incident process, or customer commitment changes.

A stale record is worse than a short record. If the facts change, update the evidence and mark what changed so the next reviewer can trust the page.