Data portability when changing OSH software

Changing software requires useful data, documents and relationships to be preserved. Contractual migration is distinct from the GDPR’s personal portability right.

In brief

Changing software requires useful data, documents and relationships to be preserved. Contractual migration is distinct from the GDPR’s personal portability right.

Contents
  1. What must be transferable
  2. Two meanings of portability
  3. Agreeing format and scope
  4. Testing before completing the exit
  5. Acceptance example
  6. Retention and service closure
  7. Related concepts
  8. References

A–Z dictionary →

What must be transferable

Leaving a preventive platform requires identifying which information must be retained and how it will be used in the destination system. Alongside records, there may be documents, versions, signatures, links and activity evidence. Downloading a spreadsheet of names and dates does not demonstrate that the file or its traceability has been preserved.

Two meanings of portability

In a technology project, portability may refer to the contractual and technical ability to export information. The GDPR right to data portability belongs to individuals and has its own conditions: automated processing and certain legal bases, among other requirements. It is not a general right for a company to receive any complete database from a provider.

Agreeing format and scope

Fields, identifiers, attachments, relationships, encodings and format documentation should be specified. Contractual costs, deadlines and responsibilities are also reviewed. A machine-readable file does not guarantee that its meaning is clear. The destination needs to know whether a date represents opening, approval or closure, and how workers, workplaces and assessments relate.

Testing before completing the exit

Migration is tested with a representative, authorised dataset. Counts, values, documents and links are compared, followed by real query tests. Data quality includes detecting duplicate records and lost relationships. Transfer requires appropriate channels and permissions, especially when health information is included.

Acceptance example

In a hypothetical example, an exported assessment preserves its text but loses the link to outstanding measures. The file exists, although the process can no longer be followed correctly. Acceptance must check that relationship and the necessary history. What happens to changes made between the first export and launch of the new system is also defined.

Retention and service closure

Completing a migration does not authorise indiscriminate deletion of data subject to retention. Access to history, appropriate return or deletion and evidence of closure should be agreed under obligations and contracts. Individuals’ rights and confidentiality continue during the change. Export should be assessed as an entire process, not merely a menu function.

References

  1. AEPD: right to data portability. Official source
  2. BOE: General Data Protection Regulation. Official source

Editorial information

Publication date: 1 November 2026.

Editorial responsibility: Sabentis Editorial Team.

Author: Pablo RodríguezLinkedIn

Executive Vice President of the ORP International Foundation and Chief Financial Officer of Sabentis.

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