AICM AtlasCSA AI Controls Matrix
DCS · Datacenter Security
DCS-01Cloud & AI Related

Off-Site Equipment Disposal Policy and Procedures

Specification

Establish, document, approve, communicate, apply, evaluate and maintain policies and procedures for the secure disposal of equipment used outside the organization's premises. If the equipment is not physically destroyed a data destruction procedure that renders recovery of information impossible must be applied. Review and update the policies and procedures at least annually, or upon significant changes.

Threat coverage

Model manipulation
Data poisoning
Sensitive data disclosure
Model theft
Model/Service Failure
Insecure supply chain
Insecure apps/plugins
Denial of Service
Loss of governance

Architectural relevance

Physical infrastructure
Network
Compute
Storage
Application
Data

Lifecycle

Preparation

Data collection, Data curation, Data storage

Development

Design, Training, Supply Chain

Evaluation

Evaluation, Re-evaluation, Validation/Red Teaming

Deployment

AI Services supply chain

Delivery

Operations, Maintenance

Retirement

Data deletion, Model disposal

Ownership / SSRM

PI

Owned by the Cloud Service Provider (CSP)

The Cloud Service Provider (CSP) is responsible for the design, development, implementation, and enforcement of the control to mitigate security, privacy, or compliance risks associated with cloud computing (processing, storage, and networking) technologies in the context of the services or products they develop and offer. The CSP is responsible and accountable for implementing the control within its own infrastructure/environment. The CSP is responsible for enabling the customer and/or upstream partner to implement/configure the control within their risk management approach. The CSP is accountable for ensuring that its providers upstream implement the control related to the service/product developed and offered by the CSP.

Model

Owned by the Model Provider (MP)

The model provider (MP) designs, develops, and implements the control as part of their services or products to mitigate security, privacy, or compliance risks associated with the Large Language Model (LLM). Model Providers are entities that develop, train, and distribute foundational and fine-tuned AI models for various applications. They create the underlying AI capabilities that other actors build upon. Model Providers are responsible for model architecture, training methodologies, performance characteristics, and documentation of capabilities and limitations. They operate at the foundation layer of the AI stack and may provide direct API access to their models. Examples: OpenAI (GPT, DALL-E, Whisper), Anthropic(Claude), Google(Gemini), Meta(Llama), as well as any customized model.

Orchestrated

Shared Model Provider-Orchestrated Service Provider (Shared MP-OSP)

The MP and OSP are jointly responsible and accountable for the design, development, implementation, and enforcement of the control to mitigate security, privacy, or compliance risks associated with Large Language Model (LLM)/GenAI technologies in the context of the services or products they develop and offer.

Application

Shared Orchestrated Service Provider-Application Provider (Shared OSP-AP)

The OSP and AP are jointly responsible and accountable for the design, development, implementation, and enforcement of the control to mitigate security, privacy, or compliance risks associated with Large Language Model (LLM)/GenAI technologies in the context of the services or products they develop and offer.

Implementation guidelines

[All Actors except AIC]
1. Providers should ensure that they have robust and clearly documented processes for the secure disposal of equipment that is used outside their physical premises, including devices that handle model development, data processing, or inference tasks. These include but not limited to the procedures listed for the CSP. If using third party datacenter vendors, ensure they have these procedures in place.

Auditing guidelines

1. Examine the organization's policy and procedures related to data destruction.

2. Determine if the policy has been approved, communicated, and reviewed.

3. Determine if a policy exists that addresses the secure destruction of data and for conditions when equipment is reused as opposed to when equipment is destroyed.

Standards mappings

ISO 42001Partial Gap
42001: A.2.2 AI Policy
42001: A.2.4 Review of AI Policy
42001: A.4.2 Resource documentation
42001: A.4.3 Data Resources
42001: A.4.4 Tooling Resources
42001: A.2.3 Alignment with other organizational policies
27001: 7.5 (7.5.1 to 7.5.3) Documentation Information
27001: A.5.1 Policies for information security
27001: A.5.4 Management responsibilities
27001: A.5.11 Return of assets
27001: A.5.37 Documented operating procedures
27001: A.6.7 Remote working
27001: A.7.10 - Storage media
27001: A.7.14 - Secure disposal or re-use of equipment
27001: A.8.10 - Information deletion
27002: 5.1 Policies for information security
27002: 5.4 Management responsibilities
27002: 5.11 Return of assets
27002: 7.10 - Storage media
27002: 7.14 - Secure disposal or re-use of equipment
Addendum

New dedicated controls or a formal extension aligned with clauses like 27001 A.7.14 and A.8.10.

EU AI ActFull Gap
No Mapping
Addendum

Mandate organizations to establish documented, approved, and communicated policies for secure disposal of off-site equipment. Require procedures to ensure irretrievable destruction of data on equipment prior to disposal or reuse. Require periodic (at least annual) review and updating of these policies.

NIST AI 600-1Partial Gap
GV-1.7-002
GV-4.1-003
Addendum

There's no reference to policies or procedures that provide explicit instructions on the removal, decommissioning, or otherwise destroying equipment used outside of the organization's facilities.

BSI AIC4No Gap
AM-02
AM-04
Addendum

N/A

AI-CAIQ questions (3)

DCS-01.1

Are policies and procedures for the secure disposal of equipment used outside the organization's premises established, documented, approved, communicated, enforced, and maintained?

DCS-01.2

Is a data destruction procedure applied that renders information recovery information impossible if equipment is not physically destroyed?

DCS-01.3

Are all policies and procedures for the secure disposal of equipment used outside the organization's premises reviewed and updated at least annually, or upon significant changes?