What happens to our electronic records when a cloud vendor or service contract ends?

When records live in a cloud service, the end of that relationship—whether the contract expires, the vendor is acquired, or the service is discontinued—can put those records at risk. The governing principle is straightforward: the organization, not the vendor, remains accountable for its records throughout their full lifecycle. A hosting arrangement changes where records sit, not who is responsible for them.

What can go wrong

If transition is not planned, several problems surface at once:

• Loss of access. Once the contract lapses, the organization may lose the ability to log in and retrieve its own content.
• Proprietary formats. Records may be stored in formats that are difficult to read outside the vendor’s platform.
• Missing metadata. Retention codes, audit trails, and other context that make a record trustworthy can be stripped away during export.
• Incomplete deletion. Copies or backups may persist in the vendor’s environment after the relationship ends.

What good practice requires

The protection happens in the contract, long before any exit. Strong agreements address records explicitly:

• Ownership. State clearly that the organization owns its records and that the vendor is a custodian.
• Exit and return. Require return or migration of all records in open, non-proprietary formats, along with their metadata, within a defined window.
• Certified destruction. Require documented, verifiable deletion of all copies after a successful handoff.
• Continuity. Address what happens if the vendor fails, merges, or sunsets the service.

Equally important, retention rules still apply during and after the move. Records under a legal hold or an active retention period must survive the transition intact; records eligible for disposition should be dispositioned only through your normal authorized process, not deleted by default because a contract ended.

The bottom line

Treat a cloud arrangement as a temporary location for records you will always be responsible for. Plan the exit before you sign, verify that you can recover complete and usable records on your own terms, and confirm that nothing lingers afterward. These same principles apply across other digital systems too—see the electronic records hub for related guidance.