Who should own data migration during implementation?

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Open questionLast verified: 2026-08-13
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  • #3425

    Vendors often provide migration tools, but the buyer understands the records and retention duties. How should ownership be allocated?

    #3426
    Accepted answer

    The buyer owns the data scope, legal and records rules, source quality decisions, reconciliation, and final acceptance. The vendor should own the contracted extraction, transformation, loading, error reporting, security, and repeatability of its migration work. Define field mappings, exclusions, exception handling, cutover, rollback, and signed reconciliation before work begins. FAR Subpart 27.4 supports defining known data deliverables and handling requirements in the contract.

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