How to Structure an Annual IT Decommissioning Plan Without Legal or Tax Risks

Introduction to IT Decommissioning

IT decommissioning is a fundamental strategic process that involves the organized removal of equipment and technological assets that are no longer in use, ensuring legal and fiscal compliance. For managers in the ESG, EHS, IT, and Legal areas, a well-structured annual plan is essential to mitigate risks and avoid legal liabilities.

Planning and Initial Diagnosis

The first step consists of detailed identification of the IT assets to be decommissioned, including a complete inventory and analysis of their useful life and operational condition. Normative requirements set forth in Law No. 12,305/2010, which establishes the National Solid Waste Policy, must also be considered, ensuring the process follows principles of shared responsibility and reverse logistics.

Fundamental Legal and Fiscal Aspects

It is imperative to ensure that the decommissioning complies with environmental regulations from CETESB and current fiscal legislation, such as RFB Normative Instruction No. 1,700/2017 on fiscal bookkeeping of fixed assets. Correct documentation of accounting and fiscal write-offs prevents fines from the Federal Revenue Service and environmental agencies.

Technical Procedures for Safe Disposal

The definitive disposal of equipment must observe information security practices, especially when involving media that store sensitive data. The process should follow the official recommendations described in NIST Special Publication 800-88 for secure media sanitization. For secure disposal of hard drives or media, scheduling is recommended through the specialized system available at hard drive sanitization.

Environmentally Appropriate Collection and Disposal

Disposal must be directed to authorized recyclers, respecting the chain of custody and certificates of proper environmental disposal. For electronic waste collection, scheduling can be done through the recognized system at electronic waste collection, ensuring compliance with environmental legislation and traceability of the waste.

Audit, Monitoring, and Continuous Improvement

Implement periodic audits to verify the legal and fiscal compliance of the plan, including document analysis and robust internal controls. Detailed records and management reports are essential tools to identify gaps and implement continuous improvements, reducing future risks.

Conclusion

An annual IT decommissioning plan should be built with a focus on legal compliance, information security, and environmental sustainability. Adherence to regulatory frameworks, combined with rigorous technical processes, ensures mitigation of legal and fiscal risks, promoting responsible management of technological assets.