ITAD Compliance Policy

One Documented Standard. Every Regulation Your Auditors Care About.

Compliance Is Not a Claim. It Is a Documented Process.

Most ITAD vendors say they are compliant. Few can show you what that actually means in writing. At Excess IT Hardware, our compliance policy is a documented standard that governs how IT equipment, data-bearing media, and electronic waste are handled from the moment your assets leave your floor to the moment they are recycled or recovered. It is the artifact your audit team can reference, your CISO can verify, and your insurance carrier can rely on.

This policy is built around the regulated frameworks our clients operate under and the environmental standards every responsible electronics recycler is held to. Every project we process is run against this policy and closes out with documentation aligned to it.

Call us at (561) 600-8656 or schedule a pickup to get this policy applied to your next ITAD project.

If your organization needs a compliant, documented approach to ITAD and electronics recycling, Excess IT Hardware is ready to support your requirements. For compliance documentation or questions related to this policy, contact our team.

EPA ID: FLR000269027
Certificate of Recycling : See sample
For more information: [email protected]

If you are ready to schedule service, request a pickup and our team will align your project to the appropriate handling and documentation requirements.

Every Framework Your Compliance Team Will Ask About

Our secure data destruction services and electronics recycling pathway are performed to meet the following regulations and standards. Match this list to your internal control framework and you will see why one provider can satisfy multiple audit obligations in a single project.

HIPAA: Protected Health Information Disposal

For healthcare clients and their business associates, the HIPAA Security Rule requires media disposal practices that prevent unauthorized access to electronic protected health information (ePHI). We perform secure data destruction services to meet HIPAA, with HIPAA-trained technicians, executed Business Associate Agreements available on request, and documented destruction outcomes that pair with your internal HIPAA program.

PCI DSS: Cardholder Data Destruction

PCI DSS requires that media containing cardholder data be rendered unrecoverable when retired. Our hard drive shredding, on-site hard drive crushing, and data erasure workflows produce destruction outcomes that align to PCI DSS requirements for media sanitization and disposal.

GLBA: Customer Financial Data

Financial institutions and any organization handling customer financial information have disposal obligations under the Gramm-Leach-Bliley Act Safeguards Rule. Our process documents the disposition of data-bearing media so your team can demonstrate that retired equipment was handled within your written information security program.

SOX: Internal Controls and Records

Publicly traded companies operating under Sarbanes-Oxley need defensible internal controls around how IT assets and the data on them are retired. Our chain of custody, asset tracking, and certificate documentation give your SOX auditors the evidence trail they expect to see attached to any decommissioning project.

FACTA: Consumer Information Disposal

The FACTA Disposal Rule requires reasonable measures to protect consumer information when records are discarded. Our secure data destruction services produce the documented outcomes that satisfy reasonable-measures expectations for any business that handles consumer reports or derivative information.

NIST 800-88: The Sanitization Standard

NIST Special Publication 800-88 is the federal benchmark for media sanitization. Our data erasure and on-site hard drive erasure workflows are performed in accordance with NIST 800-88 guidelines, covering Clear, Purge, and Destroy categories depending on the asset and the policy requirement.

DoD 5220.22-M: Multi-Pass Overwrite

For clients whose internal policies still reference DoD 5220.22-M as the sanitization baseline, our overwrite-based data erasure workflows can meet that standard. Documentation reflects the standard applied so your audit team has clarity on which approach was used per asset.

EPA, FDEP, and Environmental Compliance

Our Environmental Management System aligns with EPA standards and Florida Department of Environmental Protection (FDEP) guidance. We comply with applicable federal, state, and local environmental requirements for handling batteries, fluorescent lamps, mercury-containing devices, and other regulated materials. Our zero-landfill recycling pathway routes final material recovery through R2 Certified downstream processors.

How Our Documented Process Holds Up Under Audit

A policy is only as defensible as the operations behind it. Here is what makes ours hold.

Environmental Management System

Our Environmental Management System governs how we handle regulated materials, train our staff, and measure performance. It aligns with EPA standards and FDEP guidance and is the backbone of our pollution prevention and continuous improvement commitments.

Trained Staff and Qualified Service Providers

Our team is trained on the data security and environmental requirements relevant to their role, and we require qualified service providers to follow our e-scrap policies. This is what closes the gap between policy and practice.

R2 Certified Downstream Processors

Raw materials from processed equipment are routed to R2 Certified downstream processors as part of our zero-landfill recycling pathway. This means your project is connected to a controlled chain of custody all the way through final material recovery, with the documentation to back it up.

Continuous Improvement and Pollution Prevention

We focus on continuous improvement and pollution prevention through better planning, waste reduction, and measurable performance goals. The policy is reviewed and updated to reflect current regulations and best practices.

Frequently Asked Questions about ITAD Compliance Policy

What regulations does an ITAD compliance policy need to cover?

A defensible ITAD compliance policy needs to cover both the data security frameworks your organization operates under and the environmental requirements applicable to electronics recycling. On the data side that typically includes HIPAA for healthcare, PCI DSS for cardholder data, GLBA for financial customer data, SOX for publicly traded companies, FACTA for consumer information, and NIST 800-88 or DoD 5220.22-M as the sanitization standard your destruction methods reference. On the environmental side that includes EPA standards, applicable state regulations such as FDEP guidance in Florida, and a documented downstream chain of custody for material recovery. Excess IT Hardware addresses each of these in this policy.

No. There is no formal HIPAA certification issued at the company level. A company is HIPAA compliant when the right combination of components is in place: HIPAA-trained employees, executed Business Associate Agreements with covered entities, documented procedures that meet the HIPAA Security Rule and Privacy Rule, and verifiable destruction practices for ePHI. If a vendor calls itself ‘HIPAA Certified’ as a company-level claim, ask what specific certification body issued it. The honest answer is that no such body exists. Excess IT Hardware uses HIPAA-trained technicians, will execute a BAA with covered entities, and produces documented destruction outcomes that fit inside your internal HIPAA program.

NIST 800-88 is the current federal guideline for media sanitization. It uses three categories (Clear, Purge, and Destroy) and selects the right method based on the media type and the confidentiality requirement. DoD 5220.22-M is older and refers specifically to a multi-pass overwrite specification for magnetic hard drives. Most modern compliance frameworks now reference NIST 800-88 because it covers solid-state drives and other modern media that DoD 5220.22-M was never written for. Our data erasure and on-site hard drive erasure services can meet either standard. The certificate documents which standard was applied per asset.

ITAD compliance does not require that the ITAD provider itself hold an R2 certification. What matters for environmental compliance is that recycled materials are routed through a controlled chain of custody to processors that meet recognized standards. Our recycling pathway routes raw materials to R2 Certified downstream processors as part of a zero-landfill policy. That structure, combined with our Environmental Management System and EPA registration (EPA ID FLR000269027), gives your team the documented environmental closeout your auditors are looking for.

At minimum, auditors typically expect three artifacts. First, an inventory or chain of custody record showing what equipment was retired and where it went. Second, a Certificate of Recycling and Data Security or equivalent destruction certificate that names the standards the destruction methods reference (NIST 800-88, DoD 5220.22-M). Third, a copy of the executed BAA or vendor agreement when sensitive data is involved. Excess IT Hardware provides all three. Allow up to 30 business days for the Certificate of Recycling and Data Security to be completed after project close.

Lock In Your Compliance Documentation Today

If your organization needs IT disposal that holds up under HIPAA, PCI DSS, GLBA, SOX, FACTA, NIST 800-88, and EPA scrutiny, this is the policy that backs the work. Schedule a pickup, request the BAA if you are a covered entity, and we will align your project to the appropriate handling and documentation requirements from intake through final material recovery.

Contact us today to request a quote, schedule computer disposal pickup, or request a BAA. For compliance documentation or questions related to this policy, contact our team directly.