Data Migration Risks in Regulated Industries: too big to fail?

Data migrations are never without risk. For organizations in highly regulated sectors, like finance, healthcare, and government, the stakes are even higher. A single gap in compliance during an enterprise content migration can trigger audit failures, legal exposure, or reputational damage. How do you modernize without compromising compliance?

A data migration that cost €94,000

In day-to-day operations, compliance frameworks like GDPR, PSD2, or MiFID II are well established. But during a content migration, those guardrails are under pressure. Access rights may shift, audit trails may break, and content integrity can be harder to prove. Without a structured approach, it becomes nearly impossible to prove to regulators that your content has remained secure and intact.

In 2018, everything that could go wrong did go wrong during a data migration at the British TSB Bank. The retail and commercial bank launched a major IT upgrade, moving the records and accounts of its 5.2 million customers from a platform run by its former owner, Lloyds Banking Group, to a new system developed by its current parent company, Spain’s Banco Sabadell.

Although the data migration itself was completed successfully, 1.9 million of TSB’s 5.2 million customers were locked out of their accounts. The incident also triggered data breaches, breakdowns in digital and telephone banking, and disruptions to payment and debit card transactions. TSB’s former CIO was personally fined more than 94,000 euros for failing to meet industry compliance standards while overseeing the migration.

Content migration is about compliance

The TSB Bank case shows that moving enterprise content isn’t just a technical exercise—it’s also a regulatory challenge. During a content migration, sensitive records, user permissions, and audit trails are all in motion. Content integrity, security, and traceability must be safeguarded at every step.

But even in well-prepared organizations, compliance can slip during a migration. Most gaps trace back to three common causes:

1. Lack of traceability
   If you don’t log every step of the data migration, proving compliance after the fact becomes impossible. Regulators often ask: “Can you show me exactly what happened to this record?” Without a complete audit trail, the answer is “no”. That opens the door to fines, reputational damage, and expensive remediation projects.
2. Mismanaged permissions
   Access Control Lists (ACLs) are the backbone of secure content management. If they aren’t migrated correctly, sensitive content can suddenly become visible to the wrong people—or, just as disruptive, disappear for those who need it. Both scenarios undermine trust, violate regulations, and create business disruption.
3. Unclear scope
   When it’s unclear what should be migrated, archived, or retired, critical records often fall through the cracks. That leads to missing compliance evidence or duplicate repositories that confuse users and auditors alike. Scope creep doesn’t just slow projects down—it directly increases compliance risk.

The good news: all of these pitfalls are preventable. With a standardized content migration methodology like Xillio’s Migration Factory, you build in traceability, preserve permissions, and define scope from day one. That’s how compliance becomes a strength, not a risk.

Enter the Xillio Migration Factory

At Xillio, we built our Migration Factory approach to take the guesswork out of compliance. It’s not just a technical framework; it’s a governance-first methodology designed for complex, regulated environments. Here’s how it works:

• End-to-end auditability
  Every action in the migration pipeline is logged. From extraction to transformation to loading, you can trace exactly what happened, when, and by whom. This level of transparency makes post-migration audits straightforward.
• Role-based access control
  Our tooling automatically migrates ACLs. The same people who had access before will have access after—no surprises, no exposure.
• Compliance-ready templates
  Through our reusable Migration Streets, we apply proven mappings, validations, and reporting templates that have already been tested in regulated industries. This minimizes the risk of human error and accelerates project timelines.
• Fallback strategies
  Cutovers happen in phases with rollback options. That means critical business operations continue without disruption—even in the rare case of unexpected errors.

Ready to migrate with confidence?

If compliance risks have kept your organization from moving forward, you’re not alone. The failed IT migration at TSB Bank in 2018 showed what can happen when compliance and resilience aren’t built into the process. But with the right approach, migration doesn’t mean compromise - it means resilience.

At Xillio, we’ve guided global enterprises, government agencies, and healthcare providers  through migrations where compliance was non-negotiable. With our Migration Factory, you can unlock the benefits of Microsoft 365 while staying fully compliant every step of the way.

Ready to take control of your enterprise data migration needs? Book a call.