Technology equipment often contains parts that cannot simply be thrown away. Proper disposal of equipment is both environmentally responsible and usually required by law. Also, hard drives, USB drives, CD-ROMs, and other storage media contain various kinds of eCuras data, some of which are considered sensitive. To protect our constituent’s data, all storage mediums must be adequately erased before being disposed of. However, merely deleting or even formatting data is not considered sufficient. When deleting files or formatting a device, data is marked for deletion but is still accessible until being overwritten by a new file. Therefore, special tools must be used to securely erase data before equipment disposal.
This policy aims to define the guidelines for the disposal of technology equipment and components owned by eCuras.
This policy applies to any computer/technology equipment or peripheral devices that are no longer needed within eCuras including, but not limited to the following: personal computers, servers, hard drives, laptops, mainframes, smartphones, or handheld computers ( i.e., Windows Mobile, iOS or Android-based devices), peripherals (i.e., keyboards, mice, speakers), printers, scanners, typewriters, compact and floppy discs, portable storage devices (i.e., USB drives), backup tapes, printed materials.
All eCuras employees and affiliates must comply with this policy.
4.1 Technology Equipment Disposal
4.1.1 When Technology assets have reached the end of their useful life, they should be sent to the <Equipment Disposal Team> office for proper disposal.
4.1.2 The <Equipment Disposal Team> will securely erase all storage mediums following current industry best practices.
4.1.3 All data including all files and licensed software shall be removed from equipment using disk sanitizing software that cleans the media, overwriting every disk sector of the machine with zero-filled blocks, meeting the Department of Defense standards.
4.1.4 No computer or technology equipment may be sold to any individual other than through the processes identified in this policy (Section 4.2 below).
4.1.5 No computer equipment should be disposed of via skips, dumps, landfills, etc. Electronic recycling bins may be periodically placed in locations around eCuras. These can be used to dispose of equipment. The <Equipment Disposal Team> will adequately remove all data before the final disposal.
4.1.6 All electronic drives must be degaussed or overwritten with a commercially available disk cleaning program. Hard drives may also be removed and rendered unreadable (drilling, crushing, or other demolition methods).
4.1.7 Computer Equipment refers to desktop, laptop, tablet or netbook computers, printers, copiers, monitors, servers, handheld devices, telephones, cell phones, disc drives, or any storage device, network switches, routers, wireless access points, batteries, backup tapes, etc.
4.1.8 The <Equipment Disposal Team> will place a sticker on the equipment case indicating the disk wipe has been performed. The sticker will include the date and the initials of the technician who performed the disk wipe.
4.1.9 Technology equipment with non-functioning memory or storage technology will have the memory or storage device removed, and it will be physically destroyed.
4.2 Employee Purchase of Disposed Equipment
4.2.1 Equipment which is working, but reached the end of its useful life to eCuras, will be made available for purchase by employees.
4.2.2 A lottery system will be used to determine who has the opportunity to purchase available equipment.
4.2.3 All equipment purchases must go through the lottery process. Employees cannot purchase their office computer directly or “reserve” a system. This ensures that all employees have an equal chance of obtaining equipment.
4.2.4 Finance and Information Technology will determine an appropriate cost for each item.
4.2.5 All purchases are final. No warranty or support will be provided with any equipment sold.
4.2.6 Any equipment not in working order or remaining from the lottery process will be donated or disposed of according to current environmental guidelines.
4.2.7 Technology has contracted with several organizations to donate or properly dispose of outdated technology assets.
4.2.8 Before leaving eCuras premises, all equipment must be removed from the Information Technology inventory system.
5.1 Compliance Measurement
The Infosec team will verify compliance with this policy through various methods, including but not limited to business tool reports, internal and external audits, and feedback to the policy owner.
The Infosec Team must approve any exception to the policy in advance.
An employee found to have violated this policy may be subject to disciplinary action, up to and including termination of employment.
Revised: March 14th, 2018