SOC 2 P4.3: personal data disposal, explained for startups

What usually proves it

An auditor wants records from the period being examined, pulled from the systems that hold them rather than written up afterwards. Dates matter. A record with a date and a named owner carries more weight than a screenshot with neither. For P4.3, the usual records are these.

• Deletion logs
• Backup expiry settings
• Certificates of destruction for media

What Polara asks about it

The free readiness assessment asks one question that bear on P4.3. A yes becomes a task to show the proof. A no becomes a task to fix the gap, with the steps written out.

• Have you set how long personal information is kept, and is it deleted or anonymized when that period ends or a person asks? If yes, show it: retention schedule for personal information, a deletion job configuration, a completed deletion request, or an anonymization script with its run history. If no, the fix: set a retention period for each kind of personal information, delete or anonymize it when the period ends or a person asks, and record each deletion.

Policies, templates and connected evidence

A policy states the rule, a template gives you the record to keep, and a connected system pulls the proof from the source. An auditor checks that the three agree: the cadence in the policy, the dates in the record and what the system shows.

In the policy pack, the Privacy Program Policy covers P4.3.

Is it in your scope?

Only if you add Privacy. How you handle personal information across its life: notice, consent, collection, use, retention, access requests, disclosure and complaints. It is the heaviest category and assumes a privacy program already runs.

The scoping tool decides it with one question: Add it when you collect personal information about individuals and run a privacy program with a notice, consent and requests from the people it describes. When personal information is incidental to your service, Confidentiality is often the closer fit. Privacy notice, consent, collection and use limits, retention and deletion, access and correction requests, disclosures, breach notification and complaints.

Security is the default and always in scope. Adding Privacy in the assessment puts its 18 criteria into the report and the examination, and adds 14 questions to the assessment.

Polara Labs is not a CPA firm. SOC 2 examinations are performed by independent licensed U.S. CPA firms.

Use, retention and disposal: the criteria around it

P4.3 is one of 3 criteria in use, retention and disposal, P4.1 to P4.3. Reading a group together shows how its outcomes fit, and one record often serves more than one of them.

• P4.1, use limits
• P4.2, personal data retention
• P4.3, this page

Before it: P4.2, personal data retention. After it: P5.1, access requests. All the criteria, Security first, are on the Trust Services Criteria page, grouped by category.