FOI/EIR 25/26-535-Software Based Data Destruction Assurance

Assurance processes for software based data erasure of end of life IT equipment

Received 12 February 2026

Please provide the following recorded information held by your department regarding assurance processes for software-based data erasure of end-of-life IT equipment. For clarity, this request relates solely to software-based data destruction. Please exclude physical destruction methods such as shredding, crushing, degaussing or disintegration.
1.Please confirm whether departmental policy, contractual terms or internal procedures require an explicit outcome-based warranty or guarantee confirming that personal data has been rendered irretrievable through software-based erasure, whether carried out internally or by an external provider.
2. Where software-based data destruction is performed internally, what recorded evidential assurance does the department rely upon to conclude that the final data state is irretrievable?
3. Where software-based data destruction is performed by a third-party provider, does the department hold recorded information demonstrating that any warranty or assurance provided explicitly extends to the software erasure method used and its claimed effectiveness? If so, please confirm the recorded nature of that verification.
4. Where no explicit outcome-based warranty is required or provided, what recorded form of evidential assurance does the department rely upon to conclude that software-based erasure has rendered personal data irretrievable?
I am not requesting technical configuration detail, security sensitive information or supplier specific vulnerabilities. I am seeking confirmation of the assurance model relied upon for software-based data destruction.

Responded 12 March 2026

This information is exempt from disclosure under Section 12(1) of the Freedom of Information Act 2000. In respect of those requests that are answered in full, partially or the total refused, please take this as notice under FOIA, that we:
a) Consider the information as exempt from disclosure under the Act.
b) Claim exempt under sections of the Act:
Section 12(1) Requests where the cost of compliance exceeds the appropriate limit
c) State why the exemption applies:
12(1)(1) does not oblige a public authority to comply with a request for information if the authority estimates that the cost of complying with the request would exceed the appropriate limit.
We can confirm that individual contracts contain provisions relating to software-based destruction. However, these provisions apply to a range of software applications used across the Council and are administered by multiple departments. In order to collate the requested information, each department would need to review all relevant contracts. We estimate that undertaking this exercise would exceed the appropriate cost limit set out under the Act.