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FDIC Issues Guidance to Financial Institutions on Data Destruction

Sep 28, 20101 min
Core Java

The issue of secure data destruction is gaining critical mass.  Of course, we have had the DoD 5220-22-M Standard for a long time now.  Then came the NIST Special Publication 800-88, Guidelines for Media Sanitization (, which was firmly embraced in the healthcare context by the Department of Health and Human Services in its 2009 Guidance in connection with the new HITECH Act.  Other standards or recommended procedures followed.  The latest development is the guidance the FDIC has just issued to Financial Institutions for secure data destruction (  These various standards and guidances all make clear that organizations handling sensitive personally identifiable data must address secure destruction, both internally and in their vendor relationships.


Michael R. Overly is a partner and intellectual property lawyer with Foley & Lardner LLP where he focuses on drafting and negotiating technology related agreements, software licenses, hardware acquisition, development, disaster recovery, outsourcing agreements, information security agreements, e-commerce agreements, and technology use policies. He counsels clients in the areas of technology acquisition, information security, electronic commerce, and on-line law.

Mr. Overly is a member of the Technology Transactions & Outsourcing and Privacy, Security & Information Management Practices. Mr. Overly is one of the few practicing lawyers who has satisfied the rigorous requirements necessary to obtain the Certified Information System Auditor (CISA), Certified Information Privacy Professional (CIPP), Certified Information Systems Security Professional (CISSP), Information Systems Security Management Professional (ISSMP), Certified Risk and Information System Controls (CRISC) and Certified Outsourcing Professional (COP) certifications.

The opinions expressed in this blog are those of Michael R. Overly and do not necessarily represent those of IDG Communications, Inc., its parent, subsidiary or affiliated companies.

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