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Start with a service job, not “all customer data”

A replacement team may need current service obligations, equipment identifiers, open jobs, authorised contacts and relevant history. It may not need every prospect note, employee record or unrelated file held by the outgoing partner.

The U.S. Federal Trade Commission (FTC)’s business guidance emphasises understanding information flows, limiting what is kept and controlling service-provider access. Those security principles do not decide who owns your customer relationship or whether a particular transfer or deletion is lawful.

Sources: U.S. Federal Trade Commission: Take Stock; Scale Down; Lock It; service-provider access and retention

Define a usable and permitted handover

Make a record-category register with the responsible business and systems owners. This is an ELN continuity exercise, not a grant of access or a universal retention schedule.

Category / questionEvidence for the rehearsal
Current obligationsOpen orders/jobs, status, required follow-up and responsible company
Data and permissionsFields needed, permitted recipients/use and privacy/contract review
Usable exportFormat, identifiers, attachments and a way to verify completeness
Access transitionAccounts, keys or integrations to change through authorised administrators
Retention or returnApplicable obligations, disputes/holds and agreed return/deletion process

Prove that the next team can use the record

Fictional rehearsal: an authorised sample contains 20 open service jobs. The receiving team matches 18 to the correct equipment and obligations; two lack identifiers and three attachments cannot be opened. The sample has exposed practical gaps even though a file was exported.

Resolve the gaps and repeat the check within the approved scope. Record who verified the result and what was excluded. A sample test does not establish that the whole database is complete, accurate or legally transferable.

Coordinate continuity and access changes

Give the owner a plan for the actual exit date: required records, authorised recipients, responsible people, technical steps and unresolved legal/security questions. Avoid leaving shared credentials active simply because one export was incomplete.

Equally, do not assume every record should be erased on the last service day. Actual retention obligations, claims and rights need checking. Management dependence can assign the jobs and backups; the educational tool neither stores the customer database nor decides the permission question.

Scope

  • Commercial continuity and security preparation, not a customer-ownership decision, privacy-transfer permission, legal hold assessment or universal deletion rule.

Next step

Use Management dependence to name the records-handover lead, technical administrator and legal/privacy checker. Keep the authorised record-category register and rehearsal evidence in your own secure systems.

Sources & review notes

Access dates show when a source was retrieved. Review dates show when its meaning was checked. Editing this guide does not recheck the law.

Protecting Personal Information: A Guide for Business

U.S. Federal Trade Commission

Passage, dates and research notes

official-guidance · Take Stock; Scale Down; Lock It; service-provider access and retention

Accessed: 2026-11-15T18:14:38.355960+00:00 · Meaning reviewed: 2026-11-15T18:35:31.205811+00:00 · Next review target: 2026-12-15

Selected full sections read. Security practices do not establish ownership, transfer permission or a universal deletion date.

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