Windows 10 Recycling: A guide to security disposal and compliance

Navigating Windows 10 Sunset: A Guide to Secure Disposal and Compliance

As of January 2026, Windows 10 has officially entered its post-support era. While Microsoft ended standard support on October 14, 2025, many organizations are now finalizing the decommissioning of their legacy fleets as the one-year Extended Security Update (ESU) program approaches its final months.

For businesses, law enforcement, health care organizations, and defense contractors, simply "tossing" these machines is not an option. At Mansfield Technologies, we advocate a rigorous approach to decommissioning that aligns with the highest federal standards.

Give Old Hardware a Second Life: The Linux Alternative

Many Windows 10 machines are functionally sound but lack specific hardware components (like a TPM 2.0 chip) required for Windows 11. [2] Instead of immediate disposal, these systems can be repurposed to extend their return on investment.

Consider migrating these machines to a lightweight Linux operating system (e.g., Ubuntu, Linux Mint, or Debian). This approach is highly effective for:

• Non-Sensitive Workstations: Kiosks, training rooms, or basic internet browsing stations.

• Testing Environments: Sandbox systems for development teams.

• Legacy Application Hosts: Running specific software that doesn't require a Windows environment.

Mansfield Technologies LLC can help you evaluate which machines are candidates for migration, sanitize the existing Windows installation using NIST 800-88r2 Clear methods, and deploy a secure, stable Linux distribution.

1. Commercial Organizations: NIST 800-88r2

For general business use, the NIST Special Publication 800-88 Revision 2 (finalized in late 2025) is the gold standard for data sanitization.

Documentation:

You must maintain a "Certificate of Sanitization" for every device. This log must include the device serial number, the specific sanitization method used (Clear, Purge, or Destroy), and a verified signature of the technician.

Sanitization:

• Clear: Software-based overwriting for devices remaining in-house or being repurposed with a new OS like Linux.   

• Purge: The minimum standard for devices being sold or donated. This includes Cryptographic Erase (CE) for SSDs, which renders data unrecoverable by destroying the encryption keys. But remember you must document exactly how you purged and verified sanitization. 

• Destroy: If you operate in a highly regulated industry such as Health care (HIPAA), Financial services (GLBA), or Defense Industrial Base (CMMC); on-site physical destruction of your sensitive IT hardware is the only way you can eliminate the risk of long-term data breaches. Under these regulations there is no statute of limitations for data breaches. Many organizations in these industries have already been fined millions of dollars due to improper data sanitization. 

2. Law Enforcement: FBI CJIS Standard

Agencies handling Criminal Justice Information (CJI) must comply with the CJIS Security Policy (v6.0).

• Witnessed Destruction: Unlike commercial standards, CJIS requires that sanitization or physical destruction be witnessed or carried out only by authorized personnel.

• Rigorous Logs: Documentation must include the date and time of destruction, the unique machine identifier, and the names of both the performer and the witness.

• Sanitization: Agencies often default to physical destruction (shredding or incineration) for inoperable media or magnetic degaussing followed by physical deformation for hard drives.

3. Classified Workloads: NSA 9-12

For organizations handling national security or Top-Secret data, the NSA/CSS Policy Manual 9-12 provides non-negotiable requirements.

• Evaluated Products List (EPL): You may only use destruction equipment—such as degaussers or disintegrators—that appears on the NSA/CSS Evaluated Products List.

• Disintegration: For the SSDs found in most modern Windows 10 laptops, the NSA requires disintegration to a 2mm particle size.

• Documentation: Records must include the classification level of the hardware and a government representative’s signature supervising the release of the sanitized material.

Secure Your Transition with Mansfield Technologies

The end of Windows 10 is more than a software upgrade; it is a major data liability event. Whether you are a commercial enterprise needing to meet NIST 800-88r2 or a specialized agency requiring CJIS or NSA-level destruction, your disposal process must be airtight.

Reach out to Mansfield Technologies today to discuss your organization's unique circumstances. We provide the expertise and documentation necessary to ensure your old hardware doesn't become a future security breach.