Chapter 7 trustee's guide to a debtor's cloud accounts and SaaS records

Are a debtor's cloud accounts part of the estate?#

A debtor's cloud accounts are generally part of the estate to the extent the debtor held contract rights in the subscriptions and owned the records stored in them. The vendor owns its software, and its terms govern access, suspension and deletion, but the business records inside the account are typically the debtor's property.

Separate company accounts from personal ones early. Founders and managers often ran company work through personal Gmail, Dropbox or phone backups, and company records held there may need a turnover request through counsel rather than a password reset.

Counsel can advise whether the automatic stay or other provisions affect a vendor's ability to suspend or delete data. In practice, a prompt written request to each vendor, with the trustee's appointment documents attached, is the fastest protection.

First-month checklist: secure, stop deletion, inventory, value#

The first-month checklist runs in four stages, and the order matters because each stage protects the next. Do not export or cancel anything until the access and deletion steps are done.

Expect the stages to overlap. Vendors answer preservation requests at different speeds, so keep the inventory moving while requests are pending, but hold every export and cancellation until that system's access and deletion steps are confirmed.

• 1Secure: take control of the domain registrar and DNS, the primary email tenant, the cloud hosting account and any password manager.
• 2Secure: remove former employees' access, rotate shared credentials and log every admin change with the date and reason.
• 3Stop deletion: write to each vendor with appointment documents and ask that the account be preserved or moved to a minimum or read-only tier.
• 4Stop deletion: pause retention policies, auto-archive rules, inactive-user cleanup and scheduled purges inside each system.
• 5Inventory: list every system with its admin, billing status, record families, years of history and export route.
• 6Value: flag records needed for claims, taxes and litigation, then screen the rest for sale, license, abandonment or destruction.

How to regain admin access when the debtor's team is gone#

Admin access usually comes back through one of a few routes, and the domain is often the key. Many workspace vendors offer an admin recovery process that relies on proving control of the company's domain, so securing the registrar account comes first; check each vendor's documentation for its exact steps.

Keep a written access log from the first day. Each entry should name the system, the route used, who now holds the credentials and what changed, because creditors and the court may later ask how the trustee came to control each account.

Which settings delete records automatically#

Automated deletion settings keep running after a business stops, and they are easy to miss because nobody is watching the admin console. Check each of these before any export starts.

Document each setting as you find it, with a screenshot and the date you changed it. That record helps if a creditor later asks why some records survived and others did not.

Vendor terms add their own clocks. The examples in the table come from dated vendor documentation and change over time, so confirm each against the vendor's current terms and treat the earliest possible date as the deadline.

• 1Email retention and deletion policies in the email tenant.
• 2Message retention settings in Slack or Microsoft Teams.
• 3Ticket deletion or archiving rules in the help desk.
• 4Inactive-user cleanup that removes a departed employee's files.
• 5Storage lifecycle rules in cloud hosting buckets that expire old objects.
• 6Plan downgrades that cap history or remove features when a paid tier lapses.

Inventory and value: which SaaS records matter#

SaaS records matter to the estate for three reasons: proving or defending claims, meeting tax and employee obligations, and possible value in a sale or license. One system can serve all three, so record the purpose on each inventory row.

Avoid overstating value at this stage. Licensing value is known only once a buyer engages, so the screen should simply sort records into candidates and non-candidates before any motion is drafted.

Illustrative: a trustee secures a closed distributor's systems#

Illustrative: a fictional regional industrial distributor converts to Chapter 7 after its lender stops funding. The trustee finds NetSuite, Zendesk, Microsoft 365 and Samsara fleet telematics, all billed to a corporate card that is now declined, and the only admin was a controller who left before the filing.

The trustee secures the domain registrar, uses it to recover Microsoft 365 admin access, and writes to NetSuite and Zendesk with appointment documents asking for preservation. Retention policies are paused and full exports are verified on a separate machine.

Driver location data from Samsara is kept only as needed for claims and excluded from any value screen. NetSuite order exceptions and Zendesk tickets, which link customer problems to credits and substitutions, are flagged for a metadata-only licensing assessment before the trustee decides whether to sell, license or abandon them.

How SourceX supports trustees#

SourceX gives trustees a metadata-only fit check on operational records, run before any decision to abandon or destroy them. The trustee shares system names, years of history and record families, and no files leave the estate at that stage.

If records proceed, the SourceX five-step transaction of Supply, Rights, Preparation, Approval and Delivery runs with the trustee as approver and any required court order recorded as release authorization in the SourceX Evidence Packet. Large exports stay in storage the trustee controls or ship on encrypted drives.