Local-only learningOfficial-source trailReviewed 30 Aug 2026

SCENARIO F06 · RETENTION & ERASURE

Old customer records are moving into a new CRM. The team assumes the migration itself decides whether processing may continue. What should happen?

IN PLAIN ENGLISH

Why you are seeing this step

This field note uses one realistic decision to separate the official source, an editorial interpretation, a practical option, evidence to keep, and any uncertainty that still depends on your facts.

Educational only, not legal advice. Source status is dated 13 May 2027; inspect the official links below before relying on it.

BEST NEXT STEP

Record the processing facts and basis; if relying on pre-commencement consent, plan the Act section 5(2) notice and withdrawal path.

Do not turn a system migration into a made-up legal rule. Use it as a checkpoint to document the actual history, purpose, notice and retention facts.

WHY THE OTHER INSTINCTS MISS

Best answer

Record the processing facts and basis; if relying on pre-commencement consent, plan the Act section 5(2) notice and withdrawal path.

Correct. Act section 5(2) addresses consent given before commencement; a migration review is useful implementation evidence, not the statutory trigger itself.

Option 2

Delete every old record before the CRM migration.

The Act does not create that automatic answer. Purpose, consent history, other law and retention facts matter.

Option 3

Import everything because old consent can never be questioned.

Section 5(2) includes a post-commencement notice, and continued consent-based processing remains subject to withdrawal.

BUILD THIS EVIDENCE

Legacy-data inventory, consent/notice history, retention decision and post-commencement notice plan.

This artefact supports review. It does not certify compliance or replace advice on your facts.

Guidance type
fact-dependent
Pinpoint
Act s. 5(2), including illustration; G.S.R. 843(E)
Reviewed
2026-08-30
Change note
Status and pinpoint reviewed against the official Act, final Rules, commencement notification and corrigendum for this educational website.

OFFICIAL SOURCE TRAIL