Close access without losing the record
49 CFR 395.22 assigns account-management duties to the carrier and requires separate backup retention and protection of driver records. Deactivating an account is an access decision; deleting the records is a different action with different consequences.
Agree a departure checklist between the driver, supervisor and records owner. Handle the final record review through the authorized process. An administrator should not impersonate the departing driver or certify the driver’s day to make an offboarding task disappear.
Use an offboarding handoff sheet
| Responsibility | Completion evidence |
|---|---|
| Final record review | Outstanding days, proposed edits and the authorized person handling each issue |
| Vehicle assignment | The last assignment ended and the next driver’s identity established |
| Equipment return | Phone, tablet, cables and other issued items inventoried |
| Access change | Authorized deactivation or rights change, with date and owner |
| Retained records | Required history and separate backup retrievable by authorized staff |
Test retrieval after the access change. Ask a staff member with the appropriate records role to locate a sample date and the required history. Record the result without giving unnecessary people access to the driver’s personal information.
Keep retention decisions with the records owner
Departure does not end the carrier’s record-retention duties. Apply the required retention period and any other applicable hold before considering deletion. Do not use a device factory reset as a substitute for deciding whether the underlying records have been preserved.
This is a handoff framework rather than a claim that every Factor ELD plan has the same administrator controls. Ask which actions deactivate access, what records remain available and how backups are retrieved in the proposed configuration. ELD Record Retention: What to Keep and Why. ELD Privacy: Driver and Fleet Responsibilities.
Offboarding questions
Can the driver’s departure justify deleting the log history?
No. The carrier’s applicable retention and production responsibilities continue independently of the driver’s employment status.
Should the next driver use the departed driver’s account?
No. Establish the next driver’s proper named account and vehicle assignment. Reusing a previous driver’s identity would misrepresent who performed the work.