Active

Data Return

The organization shall return organizational data by third parties at the end of the engagement, ensuring data is returned in a usable format. Data return shall include identification of data to be returned, coordination of data transfer, verification of data completeness, and documentation of data return.

Requirement ID
TPR-005-R006
Parent Control
TPR-005
Domain Code
TPR

Requirement Details & Guidance

TPR-005-R006 · TPR-005
Why This Requirement Exists

This requirement exists to manage third-party relationships from onboarding through change, renewal, termination, data return, data destruction, access revocation, verification, and continuous improvement, specifically addressing data return, so that third-party risks remain identified, controlled, and aligned with organizational risk appetite.

Implementation Guidance

Establish and document the process for data return. Define accountable owners, required inputs and outputs, assessment or approval criteria, review frequency, monitoring, reporting, exception handling, evidence requirements, and escalation paths. Apply the process consistently across relevant third parties based on criticality, data sensitivity, service dependency, and risk.

Practical Application & Audit Readiness

TPR-005-R006 · Field Guidance

Business Examples

    Common Audit Findings

      Common Mistakes

        Best Practices & Ownership

        TPR-005 · Recommended Approach

        Recommended Practices

          Typical Owner

          Cross-Mapped Regulatory Frameworks

          Harmonized Control Mappings
          FRAMEWORK CODE FRAMEWORK NAME & DETAILS FAMILY / CATEGORY VERSION ACTION
          IRDAI IRDAI Information & Cyber Security Guidelines IRDAI information and cyber-security requirements... Clause: §2.14-3.5 – Termination; §2.14-3.6 – Data Sharing and retention
          India
          Guideline
          		 vLatest View →
          RBI-CSF RBI Cyber Security Framework / Master Directions RBI cyber-security requirements and directions set... Clause: 11) Vendor Risk Management – 11.3 Due diligence, oversight and management of third-party vendors/service providers/partners; 11) Vendor Risk Management – 11.4 Framework to assess, approve, review, control and monitor vendor/outsourcing risks and materiality
          India
          Regulation
          		 vLatest View →
          SEBI-CSCRF SEBI Cyber Security & Cyber Resilience Framework SEBI’s Cybersecurity and Cyber Resilience Framewor... Clause: 1.6 GV.SC: Cybersecurity Supply Chain Risk Management
          India
          Regulation
          		 vLatest View →
          DORA Digital Operational Resilience Act The EU Digital Operational Resilience Act establis... Clause: Article 30(2)(e) – Assistance from ICT third-party provider in ICT incidents Article 30(2)(f) – Cooperation with competent/resolution authorities Article 30(2)(j) – Access, inspection and audit rights
          EU
          Regulation
          		 vCurrent View →
          NIS2 NIS2 Directive The NIS2 Directive establishes EU-wide cybersecuri... Clause: Article 21(2)(d) – Supply chain security, including relationships with direct suppliers/service providers
          EU
          Directive
          		 vCurrent View →
          PCI-DSS PCI DSS PCI DSS is an industry security standard maintaine... Clause: 12.8.1 – A list of all third-party service providers; 12.8.2 – Written agreements with TPSPs are
          PCI
          Standard
          		 v4 View →
          NIST-CSF NIST Cybersecurity Framework (CSF) The NIST Cybersecurity Framework provides high-lev... Clause: GV.SC – Cybersecurity Supply Chain Risk Management | GV.SC-10 – Cybersecurity supply chain risk management plans include provisions for activities that occur after the conclusion of a partnership or service agreement
          NIST
          Framework
          		 v2 View →
          NIST80053 NIST SP 800-53 NIST SP 800-53 Rev. 5 presents control families, i... Clause: 3.17 – SYSTEM AND SERVICES ACQUISITION; SA-9 – EXTERNAL SYSTEM SERVICES
          NIST
          Control Catalog
          		 vRev. 5 View →
          GDPR General Data Protection Regulation (GDPR) The General Data Protection Regulation is a bindin... Clause: Article 28(3)(g) – Return or deletion of personal data after processing
          EU
          Regulation
          		 vCurrent View →
          NPCI-ISR NPCI Information Security Requirements NPCI information-security requirements define cont... Clause: Security Measures / Controls; Data Security – Deletion
          India
          Standard
          		 vLatest View →
          SOC2 SOC 2 Trust Services Criteria SOC 2 is an independent examination and reporting... Clause: CC9.2 – Risk Mitigation – The entity assesses and manages risks associated with vendors and business partners. CC6.3 – Logical and Physical Access Controls – The entity authorizes, modifies, or removes access to data, software, functions, and other protected information assets based on roles, responsibilities, or the system design and changes, giving consideration to the concepts of least privilege and segregation of duties, to meet the entity’s objectives. CC6.5 – Logical and Physical Access Controls – The entity discontinues logical and physical protections over physical assets only after the ability to read or recover data and software from those assets has been diminished and is no longer required to meet the entity’s objectives.
          AICPA
          Audit Framework
          		 vLatest View →

          Parent Domain Context

          Governance Domain Baseline
          Domain Name:
          Third-Party & Supply Chain Security (TPR)
          Purpose:
          To manage the security and privacy risks associated with third-party vendors and partners.
          Scope:
          Enterprise
          View

          Parent Control Context

          Control Baseline
          Control Name:
          Third-Party Lifecycle & Offboarding Management (TPR-005)
          Summary:
          Establishes third-party lifecycle management including onboarding, relationship management, change management, contract renewal, vendor termination, data return, data destruction, access revocation, offboarding verification, and continuous improvement.
          Business Description:
          Establish and maintain controlled onboarding, change management, contract renewal, transition, termination, data return, data destruction, access revocation, and vendor offboarding processes.
          View