When people think of GDPR, they tend to focus on active, live systems: CRM databases, file servers, live mailboxes. But what often gets overlooked is that GDPR applies equally to legacy data. That includes the emails stored in your organisation’s long-forgotten archive systems, PST files, and old mail journaling solutions.

Under GDPR, any personal data you store—regardless of where it lives—must be:

  • Searchable

  • Correctable

  • Deletable upon request

  • Protected against unauthorised access

  • Retained only as long as necessary

That means legacy email archives, even if stored offline or on deprecated systems, represent a real compliance liability. If you receive a Data Subject Access Request (DSAR), and your archives hold relevant content, you are legally required to produce it in a timely fashion. And if a data breach occurs involving unprotected legacy content? The fines can be significant.

What makes legacy archives so problematic?

  • They’re often on unsupported systems with limited access controls

  • Searches are slow, manual or incomplete

  • Data is duplicated, disorganised or retained longer than necessary

  • It’s difficult to apply modern retention or deletion policies

The longer this data remains outside your Microsoft 365 environment, the harder it becomes to manage in a GDPR-compliant way.

Migrating legacy archives to Microsoft 365 is a key step in demonstrating GDPR alignment. It brings your data under one roof, where retention policies, audit trails, encryption and access controls are consistently applied across Exchange, SharePoint, OneDrive, and Teams.

With Ultimate Migrator, organisations can securely move archived content from platforms like Enterprise Vault, HP EAS or Barracuda into Microsoft 365—while preserving metadata, message integrity and a full audit trail.

Our approach ensures:

  • DSAR responses are faster and more complete

  • Retention policies are consistently applied across all historical data

  • You reduce the risk of regulatory penalties tied to inaccessible or over-retained information

GDPR compliance isn’t just about what’s happening today—it’s about what you’ve been holding onto for the past ten years. Archive migration isn’t a nice-to-have; it’s a compliance imperative.