Checking data export and exit options before procurement

Before committing to a cloud supplier, check that your organisation can export its data and essential configuration, read the results elsewhere and retrieve them on agreed contractual terms. Confirm who can perform the export, what access they need and what happens to remaining copies.

List what must leave

Work with data and application owners to list primary records, uploaded files, object versions, metadata, database schemas, application settings, identities, audit records and recovery copies where relevant. Mark what is needed to restart the service, what must be retained for another purpose and what should be deleted; exported objects may not recreate the application that indexed them.

For each item, record its source service, expected volume, access method, format, destination and export owner. For essential settings, identities and audit records, ask the supplier to identify how each can be exported, in what format and with what access requirements.

For personal information, review the Privacy Act 1988 (Cth) and Australian Privacy Principles, particularly APP 11. The OAIC says reasonable steps to secure personal information include technical and organisational measures under APP 11.3; that subclause applies to information held after 11 December 2024, regardless of when it was acquired or created.

Include copies, backups and subcontractors in the contract review. Check how personal information can be accessed in a usable format, retrieved and dealt with at the end of the contract, including any remaining copies and backups.

The Notifiable Data Breaches (NDB) scheme requires certain entities to notify individuals and the Commissioner about data breaches likely to cause serious harm. Entities with APP 11 security obligations must comply; assess any suspected breach involving exported or retained copies under the scheme.

Check a documented path for each service

Amazon S3 supports downloads through its console, AWS CLI, SDKs and REST API. A single object can be up to 50 TB, but the console supports downloads up to 5 TB and a single GET request is limited to 5 TB; larger downloads require concurrent GetObject requests using a byte range or part number. Archived objects must be restored before downloading.

Azure Blob Storage supports AzCopy v10 downloads of blobs and directories, with suitable authorisation. Google Cloud Storage supports downloads through the console or the gcloud storage cp command; the required permissions include Storage Object Viewer for downloads, while console use also requires Storage Admin.

These methods transfer objects; they do not establish that a workload is portable. For each managed database and partner-supplied service, ask the supplier to name the supported export operation, the resulting format and the requirements to read it elsewhere. Check whether the export includes the schema and other material dependencies.

Ask the supplier to identify an export method and format for each essential application setting, identity and audit record. Check whether your organisation can obtain the required credentials and access for the export before the contract ends.

Check the contract and cost window

Establish who controls the account and credentials, when export access ends, whether assistance is included and how remaining data will be handled. Review the agreement and any applicable data-processing addendum for the terms governing data export, return, retrieval, deletion, conditions and time limits.

Google Cloud’s Cloud Data Processing Addendum is incorporated into the applicable agreement and describes the parties’ obligations for processing and securing Customer Data. Check the actual agreement and addendum for the exit terms that apply to your service; record any required export deadline rather than assuming access continues after an account closes.

For Amazon S3, downloads outside the AWS network incur data-transfer fees. Data transfer within the AWS network is free within the same AWS Region, but GET requests can be charged; data-retrieval charges may also apply. Ask for the applicable charges for your expected route, volume and service before committing, including any retrieval, temporary-storage or professional-service fees.

No single fee applies to every export route. Record the supplier’s applicable charges and assistance terms, and schedule any required retrieval within the agreed access window.

Export-related costs and constraints by provider

Propose a representative exit check

Plan an export that includes ordinary records, large items, metadata and a recovery copy where relevant. Open the result in a separately controlled destination to check it is readable elsewhere, and record what essential configuration needs to be rebuilt.

For an Azure blob with a Content-md5 value, AzCopy v10 calculates an MD5 hash for downloaded data and verifies it against that stored value. A match is the pass condition; a mismatch causes the download to fail unless the check is overridden. For other data, agree the integrity-check method and pass condition before relying on the export.

If the check is performed, record elapsed time and transfer volume. Confirm in advance that the required credentials, permissions and contractual access will be available to the people responsible for the export.

The exit decision needs four answers: what can be exported, what can be used elsewhere, who can execute it, and what happens to remaining copies. Give each unknown an owner and resolve it before relying on the exit route.