Safeguards for Proper Disposal of Hardware: Effective Inventories, Policies and Due Diligence

The SEC’s Office of Compliance Inspections and Examinations has made no secret of its emphasis on cybersecurity in the last few years. Now, as highlighted in two of its recent reports, there is a new focus: proper disposal of hardware. This article, the second in a two-part series, offers advice on practical disposal safeguards, including: creating inventories, drafting and implementing effective policies and performing due diligence on third-party disposal vendors. The first article discussed what is driving the focus on hardware disposal, the types of hardware at issue, applicable laws and guidelines and SEC examiner expectations. See “Preparing for the Latest SEC Cyber Sweeps” (Jun. 26, 2019).

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