Data may be critical
Recordings, customer histories and credentials may matter more than workstation value.
Document the handover
An export without an inventory and readability test may be incomplete.
The controller remains responsible
A customer does not lose its Russian data-law duties when its processor fails.
Asset and access map
| Object | Establish | Safe step |
|---|---|---|
| Call recordings | Purpose, retention, format and system owner | Create a lawful export and transfer record |
| CRM records | Controller and hosting location | Restrict access and verify export completeness |
| Telephone numbers | Party to the telecom contract | Arrange transfer or redirection |
| Scripts and knowledge base | Authorship and licence | Confirm continued-use rights |
| Customer equipment | Inventory numbers and delivery act | Demand preservation and recovery |
| Advance and services | Period, SLA and delivered volume | Reconcile and classify money claims |
Personal-data responsibilities
Where the customer determines processing purposes, it normally remains the controller and the call centre acts on instructions. Article 6(3) of Russian Law No. 152-FZ requires the instructions to define data, operations, purposes, confidentiality, security, audit evidence and incident notification. Processor insolvency does not cancel those duties.
Not every record is automatically owned by the customer: a third-party cloud may host the system, a telecom operator may allocate numbers, and the contractor may own scripts. Build a map of systems, rights and owners first.
Emergency transition plan
Map the environment
List telephony, CRM, storage, numbers, domains, roles and vendors.
Restrict authority
Close unnecessary accounts and rotate keys under a coordinated plan.
Create a verifiable export
Record format, period, item count and checksums.
Move customer service
Transfer numbers and channels without uncontrolled parallel processing.
Document handover
Sign the inventory, exceptions, residual copies and retention route.
File financial claims
Separate advances, unpaid services, equipment and evidenced losses.
Claim matrix
| Situation | Issue | Evidence |
|---|---|---|
| Advance for future shifts | Undelivered services | Agreement, invoice, payment and SLA |
| Partial performance | Volume and quality | Reports, recordings, metrics and notice |
| Equipment not returned | Title to specific assets | Delivery acts, serial numbers and images |
| Data partly lost | Contract and security performance | Logs, backups and incident notices |
| Data transferred but copies remain | Termination and retention | Transfer act, blocking/deletion record and legal basis |
Frequently asked questions
May the customer recover all recordings?
Only within the lawful purpose, agreement and processing instructions; format and completeness must be documented.
Must everything be deleted immediately?
Unlawful access must stop, while return, blocking, mandatory retention and deletion require a documented route.
Who owns telephone numbers?
The telecom agreement and allocation model decide this; branding alone proves nothing.
May the same CRM remain in use?
Only if the customer has the necessary licence and access; a contractor account requires lawful migration.
Primary legal sources
- Article 6 of Russian Personal Data Law No. 152-FZ
- Russian Information Law No. 149-FZ
- Russian Communications Law No. 126-FZ
- Russian Bankruptcy Law No. 127-FZ
- EFRSB insolvency notices
- Russian commercial court docket
Related guides
IT company bankruptcy · Contractor bankruptcy · Employer bankruptcy
Has a call centre stopped responding while holding recordings, credentials or equipment?
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