Module 8 · 8.2

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An exit strategy, for your new cloud too

Module 8: Backups, exit and management · Reading time: 11 minutes

Learning objective: After this lesson you can draw up and test an exit strategy, so you can leave your new provider later on without any damage, and you'll know what rights the GDPR and the EU Data Act give you in that process.

Key concepts: exit strategy, exit test, export format, open standard, notice period, transition period, returning and deleting data, Art. 28(3)(g) GDPR, EU Data Act (Regulation (EU) 2023/2854), right to switch, switching costs, domain name under your own control

Why think about leaving already?

You've only just switched, or you're still in the middle of it. Why would you think about the next switch already? Because otherwise you'll learn the lesson from this course all over again in five years' time. With your old service you ran into walls (lesson 2.3): files in a proprietary format, chats that couldn't come along, logging in through an account you wanted to close. An exit strategy makes sure you don't build those same walls with your new service.

There are also reasons you don't choose yourself: the provider gets taken over (for example by a company outside the EU, so that the questions from lesson 2.1 suddenly have a different answer), raises its prices sharply, discontinues a service, or goes bankrupt. If you have a plan, you can choose calmly. If you don't, you'll have to migrate under time pressure.

The three layers of an exit strategy

Layer one, technical: can you get your data out, in a usable format?

For each part, note down how you export it and in which format. With a service that uses open standards (lesson 2.2), this is straightforward:

Part	Export via	Format
Files	Desktop sync app, WebDAV, download as zip	The files themselves
Documents	Same as files	docx, xlsx, pptx or odt, ods, odp
Calendars	Export per calendar, or CalDAV	ICS (iCalendar)
Contacts	Export per address book, or CardDAV	vCard (vcf)
Mail	IMAP migration to the next provider	Folders and messages (eml/mbox as archive)
Chat	Export function, if available	Often JSON or HTML, only as an archive
Passwords	Export from the manager	CSV (unencrypted, lesson 7.4) or an encrypted proprietary format

Layer two, contractual: what do your agreements say about leaving?

Read this when you sign up, not when you cancel: the notice period, whether you still have full access to your data during that period, how long you can retrieve your data after the end of the contract, and when and how it gets deleted. Do you want confirmation of deletion?

Layer three, organisational: who knows how it's done?

A plan that only exists in one colleague's head isn't a plan. Put the exit strategy in a document alongside your administration, together with the administrators and the login details of the admin account (in the password manager, lesson 7.4).

What the GDPR arranges

If you use the service for other people's personal data (customers, members, staff), the provider is your processor and you sign a data processing agreement (DPA) (lesson 9.2). Article 28(3)(g) of the GDPR says that this agreement must state that after the service ends, at your choice, the processor deletes all personal data or returns it to you, and deletes existing copies, unless a law requires storage. That's your legal basis for getting your data back when you leave and having it deleted afterwards. Actually request that deletion, and ask for confirmation.

This is an explanation, not legal advice. If you're unsure about your own situation, ask a lawyer or your data protection officer.

What the EU Data Act arranges

Since 12 September 2025, the EU Data Act (Regulation (EU) 2023/2854) has applied. Chapter VI (articles 23 to 31) covers switching between cloud services and applies to providers of so-called data processing services, which includes the common online services for storage, mail and collaboration. The main points:

The provider must make switching possible and remove obstacles (art. 23), and the switching arrangements must be set out in a written contract (art. 25).
The notice period to start a switch is a maximum of two months (art. 25(2)(d)).
This is followed by a transition period of a maximum of 30 calendar days during which the provider assists and the service keeps working (art. 25(2)(a)). If that's not technically feasible, the provider must report this within 14 working days and may propose a longer period of a maximum of seven months (art. 25(4)). You may extend the transition period once (art. 25(5)).
After the transition period you have at least 30 calendar days to retrieve your data (art. 25(2)(g)), after which the provider must delete everything completely (sub h).
The provider must describe in advance which data you can take with you and in which formats (art. 25(2)(e) and art. 26).
Switching costs: until 12 January 2027 a provider may only charge reduced costs that are no higher than its own costs; from 12 January 2027 it may no longer charge any switching costs at all (art. 29). Normal subscription fees and an early termination penalty are not covered by this.

There are exceptions, for example for services largely custom-built for a single customer, and for trial versions (art. 31). So the Data Act makes switching easier, but it doesn't export your data for you. An export format that nobody else can read remains a problem, which is why open standards still matter.

Your domain name: the most important key

One thing makes every exit much easier: your own domain name, under your own control. If your email address is info@example.com and the domain name is registered in your organisation's name, you can move your mail to any provider by changing the MX records (lesson 4.3). If your address is bakkerijdekorrel@gmail.com or the domain name is locked into your provider's account, you lose your address when you leave, or you depend on the provider's cooperation.

So check:

whether the domain name is registered in the organisation's name (as the holder), not in the name of a former employee or web builder;
whether you know which registrar it's with and how to request the transfer code;
whether your cloud uses an address on your own domain, such as cloud.example.com, so that apps and links don't depend on an address belonging to the provider.

The exit test

You test an exit strategy the same way as a backup: by actually doing it, on a small scale. At De Korrel, Ruud does this once a year, on a quiet afternoon:

He exports one folder of documents, the shared calendar "Delivery" (ICS) and the address book "Suppliers" (vCard).
He opens those files in a different environment: a different calendar application, a different address book, a different office suite.
He checks: do the appointments come through with the right times and recurrences? Are the phone numbers linked to the right names? Do the documents open with the right formatting?
He notes what didn't work, and adjusts the strategy.

In exercise A8.2, you'll have a program check this automatically.

In practice: what this looks like with a provider

A WebOké Nextcloud works with open standards: you retrieve your files with the desktop app or WebDAV, you export calendars as ICS and contacts as vCard, and documents are stored as docx, xlsx, pptx or odt among your files. The manual also describes how to switch from another Nextcloud provider using the desktop app and ICS and vCard files; the same route works the other way round too. Mail is held in a mail package that you can copy to any other provider using IMAP. Domain names can be transferred to another registrar using a transfer code.

With other European providers it works in a similar way, as long as they use the same open standards. Ask before you sign.

Summary

Plan your departure from the start: technically (export formats), contractually (notice, return of data, deletion) and organisationally (who knows how).
Art. 28(3)(g) GDPR: return or delete data after the end of the service, at your choice.
The Data Act: notice period of at most two months, transition period of at most 30 days (exceptionally seven months), at least 30 days to retrieve your data, and no switching costs from 12 January 2027.
Your own domain name, under your own control, is the most important key to any exit.
Test your exit once a year, on a small scale.

Quiz

Exercise

Exercise A8.2: Exit test with automatic check. Export one calendar (ICS), one address book (vCard) and a few documents from your new service, and upload them as a zip or as separate files. The program checks whether the files are valid and in an open or common format, and compares the counts with what you report.

Exercise A8.2: Exit test with automatic check

File for this exercise: testagenda.ics, testcontacten.vcf

In your service, create a test calendar and a test address book with a few items and a few test documents, export them and upload the export: one zip or the separate files (each no more than 2 MB). Fill in how many appointments, contacts and documents your service shows. The program checks whether the export path works and whether anything is lost along the way. We don't show file names or content.

Number of appointments in the exported calendar

Number of contacts in the address book

Number of documents

The whole export as a zip (optional)

Please upload a test file with fake data rather than your real data. The file only stays in memory while it's being checked; we don't store it.

Or separately: calendar (.ics) (optional)

Please upload a test file with fake data rather than your real data. The file only stays in memory while it's being checked; we don't store it.

Contacts (.vcf) (optional)

Please upload a test file with fake data rather than your real data. The file only stays in memory while it's being checked; we don't store it.

Document 1 (optional)

Please upload a test file with fake data rather than your real data. The file only stays in memory while it's being checked; we don't store it.

Document 2 (optional)

Please upload a test file with fake data rather than your real data. The file only stays in memory while it's being checked; we don't store it.

What you enter and what we find isn't stored. Your browser remembers your answers and whether you've passed the exercise. If you're signed in, we only save that you got the exercise (almost) right in My courses; you can delete that there too.

Exercise E8.2: Your exit strategy on a single page. Fill in, for each part, how you export it and in which format, look up the notice period and the arrangements for returning and deleting data in your contract or terms and conditions, and check who the domain name is registered to.

Exercise E8.2: Your exit strategy on a single page

Fill in your exit strategy using your own service and your own contract.

Per part (files, documents, calendars, contacts, mail, chat, passwords): how do you export it, which format, open standard yes/no, who can do it, tested on (date).

What is the notice period, and can you still fully access your data during that period? For how long can your data still be retrieved after the end?

Does the data processing agreement state that the provider returns or deletes data afterwards? Do you ask for confirmation of deletion?

Whose name is your domain name registered under, with which registrar, and do you know how to request the transfer code?

Where is this document kept, and who knows about it?

Your ticks and notes only stay in this browser; we don't send them anywhere. If you're signed in, we only save in My courses that you've done the exercise.

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