Separate record preservation from importing data
An exported file, a readable archive and an imported record inside a new application are different outcomes. Agree which one is needed for each record set. Do not describe an archive as a successful import or assume a new provider accepts every field from an old system.
The carrier’s obligations include preserving originals and meeting applicable retention and production requirements. See 395.30(f), 395.22 and 395.8. A supplier change does not remove those duties.
Build a source-to-destination verification sheet
| Record set | Source evidence | Destination check |
|---|---|---|
| Driver and vehicle identity | Identifiers used by the original system | Documented mapping without mixing two people or trucks |
| Required dates | Date inventory and known gaps | Every required period accounted for |
| Original events and changes | Available original, annotation and review history | Preserved history, not only a summary total |
| Time reference | Home-terminal settings and export time representation | No unexplained date or time shift |
| Retrieval | Original filename, export date and access owner | Authorized staff can open and interpret a sample record |
Keep a manifest of the files received, their covered dates and where the protected copies are stored. A file count alone is insufficient: ten files can contain duplicate dates while a required day is missing.
Investigate a mismatch before closing the old account
Compare the source and retained version for a sample day, then expand the check when a discrepancy appears. Record whether the issue concerns missing data, identity mapping, date boundaries, format interpretation or access permissions. Preserve the untouched source export while resolving it.
Ask the provider to explain any import limitation in writing. This guide does not promise that Factor ELD imports another supplier’s full audit history. A retained external archive may still need its own access and retrieval process.
Record who accepts the handoff
Name the records owner, the person who verified retrieval and any unresolved gap. Confirm required driver access during the changeover as well as office retention. Only then follow the authorized plan for closing old access. Switching ELD Providers: A Fleet Transition Plan. ELD Record Retention: What to Keep and Why. Backing Up and Restoring ELD Records.
Migration questions
Is a PDF summary the same as the original ELD data?
Do not assume so. Identify which information and history each format preserves and whether it satisfies the intended recordkeeping and production purpose.
Can we delete source exports after the new account opens?
A working account is not proof of complete preservation. Apply the retention requirements and any holds, and verify the retained record set before an authorized deletion decision.