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OBJECTIVE & SCOPE
This policy defines the mandatory requirements for decommissioning, data sanitization, and disposal of all technology assets owned by the Library. It ensures compliance with federal IRS regulations, Virginia public trust laws, maximizes the lifecycle of public and donor-funded assets, and minimizes environmental impact.
This policy applies to all hardware tracking data or containing storage media owned by the Library, including desktops, laptops, tablets, servers, network infrastructure, printers, and mobile devices.

DECOMISSIONING & ASSET TRACKING
Before any hardware leaves the premises, the IT Department must execute the following tracking steps:

• Log Removal: Update the central asset management database status to "Decommissioned."
• Record Details: Document the asset tag number, serial number, device model, and date of removal.
• Remove Labeling: Physically remove all library asset tags, barcodes, and identifying institutional stickers from the chassis.

MANDATORY DATA SANITIZATION
Protecting patron and staff data is the highest priority. No device may be disposed of, donated, or recycled without certified data destruction.

• Storage Drives: All hard drives and solid-state drives (SSDs) must be wiped using industry-standard software (NIST SP 800-88 compliant erasure).
• Physical Destruction: Drives that fail the software wipe process, or cannot be accessed, must be physically destroyed via crushing, shredding, or degaussing.
• Configuration Clearing: All network hardware, printers, and smart devices must be reset to factory defaults to erase saved Wi-Fi keys, configurations, and cached user data.

DISPOSAL HIERARCHY
The Library prioritizes resource conservation and community benefit. Decommissioned equipment must be routed through the first applicable category below:
 

Tier 1: Internal Reallocation
Can parts of the equipment (such as RAM, storage drives, or power supplies) be harvested to repair or upgrade other active library systems? If yes, salvage parts and stock them in IT inventory.
 

Tier 2: Community Donation
If the equipment is fully functional but no longer meets library performance standards, it may be donated to local registered non-profits, schools, or low-income digital literacy programs.

• Recipients must sign a "Donation Liability Waiver" stating the hardware is accepted "as-is" with no ongoing IT support or warranties provided by the Library.

Tier 3: Certified E-Waste Recycling
Hardware that is broken, obsolete, or unsafe for reuse must be sent to an electronics recycling vendor. The vendor must hold active R2 or e-Stewards certifications.

• The IT department must obtain a formal Certificate of Destruction from the vendor for every batch of equipment recycled.

COMPLIANCE, ETHICS, AND CONFLICT MINIMIZATION
To comply with Internal Revenue Service (IRS) regulations regarding Private Inurement and Excess Benefit Transactions (IRC § 4958), and to protect assets held in public trust under Virginia law, strict disposal rules apply to library insiders.

• Prohibition on Private Benefit: No decommissioned library IT equipment may be sold, gifted, or transferred directly to active employees, management, board members, or their immediate family members.
• Public Resale Channel: If the IT Department determines that decommissioned equipment still holds a Fair Market Value (FMV) exceeding $100 per unit, it must be listed via an open-market public auction platform (e.g., GovDeals or eBay). Library employees may bid on items only through these public platforms as standard members of the general public.
• No Trash Disposal: No electronics may be thrown into standard trash bins or dumpsters due to environmental regulations regarding heavy metals.

POLICY ENFORCEMENT & REVIEW
Failure to adhere to this policy may result in disciplinary action up to and including termination. This policy will be reviewed annually by the IT Department and the Board of Trustees to ensure alignment with changing federal, state, and environmental regulations.

Click here to download the full policy