IT disposal companies - What you need to know
There are now over 400 registered IT disposal companies, the majority of which have been established within the last 12 months to coincide with the introduction of the WEEE Directive. What is of most concern is that an alarming number of these companies are not providing a bonafide service, which could leave you liable.
Legislation regarding IT disposal (WEEE Directive) is somewhat of a minefield, so to assist you we have put together a number of basic questions to ask and information you should request before deciding to use any IT disposal company.
1) Do they have a Waste Carrier license?
Mandatory legal requirement.
2) Do they have a Waste Management license?
Mandatory legal requirement. If a disposal company tells you they have an exemption this is no longer valid. Any company dealing with the processing of redundant IT equipment has to have a Waste Management license, simple as that.
3) Can they provide a sample Hazardous Waste Consignment Note?
Historically referred to as a Duty of Care Transfer Note, this is a legal document which needs to be completed and signed by both parties on the day your equipment is collected. This form should detail as a minimum
- Address for both companies
- Consignment note code
- Customer premises code
- SIC code
- EWC codes and quantities collected for each code
- Vehicle registration
- Date and time of collection
- Signatories from both companies
- Disposal company licence
- Recovery process code
4) Can they provide a sample asset report?
Although not a legal requirement a reputable disposal company should provide you with an asset report providing you with a detailed breakdown of equipment collected. A useful report will include:
- Equipment make & model
- Equipment specification
- Serial number
- Customer asset number
- Grade or condition
- Percentage of raw materials harvested through recycling
5) Can they provide a sample data erase certificate?
There have been a number of high profile cases over the years where leading companies have fallen foul of the data protection act by allowing sensitive and/or privileged information to reach the public domain. In most cases this can be traced back to the IT disposal company who simply did not take appropriate measures to erase or safeguard their client’s information.
Our data erase software is recognized to UK Government Restricted Standard and we produce a certificate for every hard drive detailing the drives make and serial number. Ask your prospective disposal company for a sample certificate.
6 ) Do they use their own vehicles and drivers?
In terms of sensitive data your equipment is at its most vulnerable between the point of collection and return to the disposal company, yet many IT disposal companies (including some well known ones) continue to use 3rd party carriers to collect customer’s equipment, although they won’t always tell you this at the time. Ask your prospective disposal company to confirm their transport arrangements.
As a guide we only ever use our own liveried vehicles which are satellite tracked. Our drivers are security cleared and uniformed. In addition we give our customers an exact date and estimated time of arrival.
7) What you need to do.
It is illegal for an IT disposal company to remove redundant IT equipment from your site if you do not have a premises code. A premises code is basically a licence issued by the Environment Agency, which allows you to dispose of redundant IT equipment for a period of 12 months. Cost is £18 per site and you can register with the Environment Agency here.
Alternatively your IT disposal company may do this for you. CDL can do this for you for £18 plus a £2 admin fee.
Please note you do not need to apply for a premises code if your company is disposing of less than 200kg of Hazardous Waste within a 12 month period. To help you define what constitutes hazardous waste you can take guidance from the following link http://publications.environmentagency.gov.uk/pdf/GEHO0506BKTR-e-e.pdf
Please note that the points raised above are merely a guide and if you have any concerns or further questions please contact either CDL or the Environment Agency directly.
