Audit‑ready on‑site wipes for 1,200 PCs and 40 servers under NIST 800‑88, with full chain‑of‑custody and certificates within 48 hours.
Client. Multi‑site office consolidation (Tokyo + Kobe)
Context
Two offices were being consolidated at quarter‑end with strict privacy obligations. Existing inventory data was incomplete, and legacy devices spanned multiple vendors and drive types. We needed an IT asset disposition (ITAD) program that could run on‑site, meet NIST 800‑88, and survive audit.
Challenge
- Quarter‑end decommission with strict privacy and audit controls
- Incomplete inventory and mixed device types increased chain‑of‑custody risk
- Tight schedule across Tokyo/Kobe sites and building access windows
Approach and rationale
We prioritized on‑site erasure to avoid data leaving premises, aligning to NIST 800‑88 Clear/Purge requirements per media type. Chain‑of‑custody was enforced from pickup to certificate issuance, with role separation and dual‑person verification.
Implementation
- Staging by zone with barcode intake; serialized IDs reconciled to source inventory
- NIST 800‑88 erasure with verification logs; physical destruction only for failed media
- Evidence pack: photos of device/serial, erasure results, and custody signatures
- Tamper‑evident seals and locked transfer bins; secured overnight storage
- Site playbooks localized for each building (access, loading docks, escorts) and integrated into the daily run sheet
- Real‑time dashboard of intake/erase/verify/dispatch stages; exceptions triggered paging to leads and privacy officer
Reporting and evidence
- Daily exports with inventory deltas, chain‑of‑custody signatures, and wipe logs per device
- Certificate bundles grouped by cost center; finance feed for value‑recovery postings
- Quarterly template refined to standardize future ITAD runs across sites
- KPI pack published weekly: wipes per day, exception rate, certificate SLA, value recovery by lot
- Secure logistics with manifest sign‑off at each hand‑off; proof of pickup/delivery
- Remarketing triage for value recovery; WEEE/compliance and customs checks
- Data‑erasure scope and NIST 800‑88 levels documented per asset class (Clear/Purge)
Risk management and governance
- Dual‑person sign‑off at erase and dispatch; role separation between erase/verify
- Daily audit trail exports; exception queue reviewed in stand‑ups
- Privacy officer approval for any deviation; DPIA on flows
Outcomes
- Zero data‑loss incidents; 100% certificates issued within 48 hours
- Finance received monthly value‑recovery postings mapped to cost centers, and auditors reviewed a randomized sample of device logs against custody signatures without findings.
- −37% net program cost via value recovery; landfill avoidance through reuse
- Audit‑ready evidence trail accepted by internal/external auditors
- Stakeholders received weekly briefings summarizing wipe counts, exception resolutions, and certificate issuance status per site, maintaining transparency and pace.
Timeline
Three weeks staged by site, with nightly pickups and weekend waves; building access deconflicted in advance
Technology
Certified NIST 800‑88 erasure tools, barcode scanners, secure logistics, evidence pack and ERP reconciliation
Next steps
Extend the playbook to remaining sites and standardize intake templates. Related services: ITAD, IT Consulting & Project Management. See our blog for asset lifecycle posts.