Who owns our AI memory when a member of staff leaves?
By Gary Dhanda · 11 November 2026 · 3 min read
Short answer
In practice the answer is whoever controls the account. If a colleague used a personal account the firm may not be able to see or move what it remembers. On a business plan the admin has more controls. Who legally owns the content is a separate question for your adviser. The practical fix is to keep the firm's know-how in a document the firm owns and to use accounts the firm controls.
Why this matters
A colleague who has used an AI tool for a year will have taught it how the firm quotes, writes and talks to clients. That sits in their account. When they leave, the account goes with them unless the firm controls it.
Step 1: list the accounts
Ask each person which AI tools they use for work and whether the account is personal or provided by the firm. Write the list down with the date. You cannot manage what you have not listed.
Step 2: keep the know-how in a document
Follow the steps in our guide on setting up an AI memory. One document, one owner, loaded into each tool. If a person leaves, the document stays.
Step 3: check what each plan lets an admin do
OpenAI says Enterprise account owners can turn memory off for the organisation. Anthropic says Enterprise admins can do the same and that users can export their memory. Google says Workspace admins control whether users can delete Gemini conversations and how long inactive ones are kept.
These are controls over memory and history. The pages we read do not say an admin can read an individual's memories, so check that with your provider.
Step 4: tidy before they go
Ask the leaver to review what the tool has saved and remove client personal details. UK GDPR Article 5 says personal data should be limited to what is needed and kept no longer than needed, and a leaver's account is a good time to apply that. Our six checks cover what stays out.
Step 5: close the loop
Add the AI accounts to your leaver checklist next to email and laptops. Put a date in the diary to confirm they were closed or moved.
Where this leaves you
Memory belongs where you can reach it. A document the firm owns and accounts the firm controls get you most of the way.
This is a general guide, not legal advice. For who owns the content in law, speak to your solicitor. If you would like help setting this up, get in touch through our Contact page.
Sources
OpenAI, 'Memory and new controls for ChatGPT', openai.com/index/memory-and-new-controls-for-chatgpt, 13 February 2024 with later updates. Read 11 November 2026.
Anthropic, 'Bringing memory to Claude', claude.com/resources/articles/memory, 11 September 2025. Read 10 November 2026.
Google Workspace Admin Help, 'Manage Gemini in Workspace conversation history settings', knowledge.workspace.google.com, last updated 26 October 2026. Read 11 November 2026.
UK GDPR, Article 5(1)(c) and (e), legislation.gov.uk/eur/2016/679/article/5. Read 10 November 2026.