Policy for Collection and Disposal of IT Waste
Key points:
- On removal from the school, IT Equipment is immediately transported to Vital’s premises.
- On arrival at Vital’s premises the data is wiped from the IT Equipment.
- Where Vital are carrying out a large scale replacement of IT Equipment, the data will be wiped from the IT Equipment before it is removed from the school.
- Once the IT Equipment has been wiped, it is stored in a secure location at Vital’s premises.
- IT Equipment which is to be disposed of will be collected from Vital’s premises for recycling by an accredited IT recycling company.
- Peripheral equipment will be collected for disposal by a waste collection company.
- Where Vital own the IT Equipment they may, once the data has been wiped from it, reuse it or supply it to another customer.
Purpose of the Policy
This policy sets out the procedures which Vital York Limited (Vital) have put in place to comply with its obligations under the UK GDPR, Data Protection Act 2018 and The Waste Electric and Electronic Equipment Regulations 2013 (as amended). The key points of the policy are set out above but Vital recommend that you read the whole policy to ensure you understand our processes and procedures.
1. Definitions
In this policy the following words and phrases shall have the following meanings:
- Data means the data stored on the IT Equipment.
- IT Equipment means computer hardware which is owned by the School or which is owned Vital and leased to the School.
- Peripheral Equipment means equipment used in association with the IT Equipment but which doesn’t store data (e.g. printers, computer mice, keyboards etc.)
- School means the school or other educational establishment who is Vital’s customer.
- Secure Location means the locked room at Vital’s premises in which IT Equipment is stored.
- WEEE Regulations means The Waste Electric and Electronic Equipment Regulations 2013 (as amended)
2. Removal and Collection of IT Equipment
These procedures apply where the IT Equipment being removed is not part of a large scale replacement of IT Equipment. The IT Equipment will be removed by Vital employees who will log the serial numbers of the IT Equipment. Where appropriate Vital will also remove the associated AC adapters. The IT Equipment will be placed in a [secure] central location on the School’s site. iPads will be wiped to erase the Data before the iPad is removed from the School. The IT Equipment will be loaded into a Vital van for transportation to Vital’s premises. The van will not make any stops on the way. All of Vital’s vans are fitted with GPS trackers [which are regularly monitored].
3. Large Scale Replacements of IT Equipment
When Vital is carrying out a large-scale planned replacement of IT Equipment the Data on such IT Equipment will be erased before it leaves the School’s site. Large scale replacement projects are planned so that a Vital employee attends the School the evening before the replacement is due to occur, to carry out the erasure of data on all of the IT Equipment which is to be replaced. If it is not possible to erase the data on iPads they will be returned to Vital’s premises but a PIN will be added to the iPad before it is removed from the School’s site.
4. Erasure of Data
When the IT Equipment containing Data arrives at Vital’s premises the Data will be immediately erased except where there are circumstances which require continued access to the Data in which case the IT Equipment will be placed in the safe storage room. Data is erased using the internal wipe settings on the IT Equipment. Vital have assessed the tools necessary to erase the data which is likely to be stored on the IT Equipment and determined the steps which are necessary to remove this data from the IT Equipment. For example, Chromebooks are wiped by carrying out a Powerwash which erases all of the information on the Chromebook’s hard drive including settings, apps and files. For Windows IT Equipment Vital uses Microsoft DaRT to carry out a data wipe. Vital will carry out a one pass data wipe. For iPads, a second check will be carried out by other members of Vital’s team to ensure all data has been removed.
5. Secure Location
Vital have a locked room at its premises to store IT Equipment. Vital have enhanced the security on the Secure Location by doing the following:
- Installing a CCTV camera which records all persons accessing the Secure Location:
- Installing a keypad with a code which must be inputted to access the Secure Location. Only four members of staff have the code for the keypad: and
- Limiting the members of staff who have a key to the Secure Location.
Vital have taken appropriate measures to ensure its premises are secure. These measures including shutters which are closed when no one is working in the building, an alarm system and internal and external CCTV.
6. Disposal of IT Equipment
IT Equipment is collected by Recycle IT Limited who provide IT recycling services to Vital. The IT Equipment is transferred from the Secure Location to Recycle IT’s vehicles. Recycle IT have appropriate accreditations including ADISA, ISO9001, ISO14001 and ISO27001. Vital have a data processing agreement in place with Recycle IT. On completion of the recycling of the IT Equipment, Recycle IT provide Vital with documentation which confirms that compliance with the WEEE Regulations. Peripheral Equipment is collected by EnviroElectronics from bins located outside Vital’s premises. A waste transfer notice (as required by the WEEE Regulations) is provided to Vital. EnviroElectronics is appropriately licenced and registered for the disposal of IT waste.
7. Reuse of IT Equipment owned by Vital
IT Equipment owned by Vital will be wiped at Vital’s premises to remove the Data. Once the Data has been removed, Vital may sell such IT Equipment, supply it to other customers or use it for spare parts.
8. Queries or more information
If you have any queries about this policy or require more information about any aspect of the policy please contact Steve Pattison at sp.pattison@vitalyork.com
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