What should the return and deletion outcome cover?
Start with the trigger and authorized outcome: a customer instruction, purpose expiry, retention-schedule event, contract termination, or valid legal requirement. Then define the export format and verification, timing, contract-end recovery buffer, erasure method, live systems, temporary files, logs, backups and continuity copies, subprocessor copies, archives, legal holds, and completion notice.
ISO/IEC 27018 recognizes return, transfer to another processor or controller, secure deletion or destruction, , and archival as possible dispositions. Return or transfer requires a usable export and confirmed recipient; deletion or destruction requires a defined mechanism; anonymization requires evidence that the result is no longer identifiable by reasonably likely means; archival requires a valid purpose, restricted access, and a retention end. None should be used to avoid a required return or deletion.
- State the retention period after contract termination that protects against accidental lapse without turning the buffer into indefinite retention.
- Specify the disposition mechanism in the contract, such as de-linking, overwriting, demagnetization, physical destruction, or another applicable commercial standard.
- Apply a documented age limit and periodic cleanup to unused temporary files.
Citations (3)
- ISO/IEC 27018:2025 standard page
Primary ISO listing for the 2025 edition of ISO/IEC 27018.
Guidelines for protection of personally identifiable information (PII) in public clouds acting as PII processors
- ISO/IEC 27018:2019 standard page
ISO's withdrawn 2019 listing identifies the prior edition; its detailed clauses remain relevant only when that edition is the stated criterion.
Code of practice for protection of personally identifiable information (PII) in public clouds acting as PII processors
- GDPR consolidated text
Binding EU data protection regulation used for ISO/IEC 27018 comparison.
at the choice of the controller, deletes or returns all the personal data to the controller after the end of the provision of services relating to processing, and deletes existing copies unless Union or Member State law requires storage of the personal data