Law firms, accounting firms, M&A advisers, consultancies and agencies hold other people's secrets. Before you sell a copy of your records for AI training, the question is not only what you own. It is what you promised your clients.
Last checked: October 7, 2026. For companies, not for individuals selling their own data.
micro1's page says the company keeps ownership of its underlying data. Mode says it buys an agreed copy and the originals stay with you. Neither statement touches the harder question for a professional firm: what you agreed with the people whose matters fill your systems.
A 25-person accounting firm owns its servers, its practice software and the emails its staff wrote. Those emails are full of clients' revenue figures, payroll, tax positions and family details. A law firm's document system is mostly client matters. An M&A adviser's drive holds data rooms that belong to the companies being sold. An agency's project folders hold drafts the client may own outright under the contract. Owning the storage does not give you the right to license the contents.
That is why the buyer programs' own privacy statements, useful as they are, cannot settle the matter. They describe what the buyer does after you hand over a copy. Your duties to clients apply before that moment, and many of them do not depend on whether names are removed later.
Information a client gave you, or that you created while working for a client, that you agreed to protect through a contract, an engagement letter, a professional rule or a law. The duty usually covers the information itself, not only the client's name.
Most firms have all four. Each one needs its own check.
NDAs, engagement letters, master service agreements and data processing agreements. Many limit use to "performing the services" and bar disclosure to third parties. Some survive the end of the relationship.
Attorney-client privilege and work product protect certain legal communications. Sharing them with a third party can put that protection at risk. Ask your lawyer before any privileged material leaves the firm.
Lawyers' confidentiality rules (the ABA Model Rule 1.6 is the common model), the AICPA Code of Professional Conduct for accountants, and Internal Revenue Code section 7216 for tax preparers.
Your clients' files contain their employees' and customers' personal data: CCPA/CPRA, GDPR, GLBA for financial data, HIPAA for health data. Health data has its own rules.
The eligibility column shows only what buyers publish. The questions are for your lawyer.
| Firm type | Typical records | Published eligibility | Question to ask first |
|---|---|---|---|
| Law firms | Matter files, client email, drafts, court filings, billing narratives | Mode: law firms with 6+ employees | Which of our records fall outside privilege, work product and our confidentiality rules? Has our state bar issued ethics guidance on this kind of use? |
| Accounting and tax | Ledgers, reconciliations, returns, client correspondence, close checklists | Mode: accounting firms with 10+ employees | Does section 7216 reach any of this? What do our engagement letters say about disclosure and use? |
| M&A and corporate finance | Data rooms, valuation models, buyer lists, deal memos | No firm-type rule published; general minimums apply | Which NDAs cover each deal, and do they survive closing? Who owns the data room contents? |
| Marketing and creative agencies | Briefs, revisions, approvals, deliverables, client feedback | No firm-type rule published; general minimums apply | Do our client contracts assign drafts and deliverables to the client? Are there confidentiality clauses on briefs? |
| Consulting | Methodologies, deliverables, interview notes, client data extracts | No firm-type rule published; general minimums apply | Which parts are our own methodology, and which are client material under NDA? |
Sources: data.mode.inc (law and accounting minimums), checked October 7, 2026. micro1 publishes a general 30+ employee requirement; see buyer programs compared for all published rules. More detail for two sectors: law firms and accounting firms.
How the same question plays out in five kinds of firm. Each ends with what typically survives review, which is a starting point for your lawyer, not a conclusion.
Almost everything in the document management system is a client matter, and most client email is privileged or confidential. Billing narratives describe legal work for named clients. The practical scope shrinks to what the firm wrote for itself: intake checklists, matter-opening procedures, conflict-check workflows, internal training, research memos on general points of law with client facts removed, and knowledge-management pages. Ask ethics counsel whether even anonymized precedent documents can leave the firm.
Close checklists, reconciliation procedures, review notes templates and the workflow of how a return moves from preparer to reviewer are often the firm's own. The client ledgers, returns and the email threads about them are not. Tax return information raises the section 7216 question for preparers. A realistic scope is the process layer: how work is done, checked and signed off, with every client figure stripped out.
Deal work runs on NDAs with sellers, bidders and financing parties, and many survive closing. Data rooms belong to the company being sold. Even a de-identified deal memo can point to a real transaction in a small market. What may remain: your own process playbooks, model templates without client inputs, and internal training on how a sale process is run.
The revision history of a campaign, briefs, feedback rounds and approvals are exactly the decision trail buyers describe wanting. But client contracts often assign deliverables and sometimes drafts to the client, and briefs may be confidential. Check each master agreement. Internal process documents, project management workflows and your own pitch methodology are easier to clear than client work.
Your methodology may be yours, but the deliverables, interview notes and client data extracts that show it in use usually are not. Separate the frameworks and templates you developed in-house from anything produced under a client engagement. Ask your lawyer whether general know-how learned on engagements can be described without breaching client NDAs.
The firm's own process layer is the part most likely to clear. Client content is the part most likely to be blocked. Value sits mostly in the second, which is why honest scoping often produces a smaller deal than a firm first hoped for.
The left column is a cautious default for regulated and client-service firms. The right column still needs review before anything is exported.
Be honest with yourself about value. micro1 lists SOPs, knowledge bases, internal documentation and QA processes among what it wants, so firm-owned process material is in scope for at least one program. It is also less unique than a full record of client work. Removing client content lowers the risk and usually lowers the price. Practitioners say raw data is the cheapest tier in any case, so do not let a hoped-for number push client material back into scope.
Buyers publish de-identification steps. Confidentiality duties often reach further than names.
A memo about an unannounced acquisition can reveal the deal with every name replaced. A client's pricing strategy is still the client's strategy without its logo. Ask whether your obligations cover the substance.
A regional firm with a few large clients can be identified by context: industry, size, location, dates. Pseudonyms do not remove that context.
When you hand over a copy for the buyer to de-identify, the raw material leaves your control for that processing step. Ask your lawyer whether that handover is itself a disclosure under your client agreements.
If sharing waives privilege, later scrubbing does not restore it. That risk sits with the firm and its clients, not the buyer.
Do this before you share a manifest with any buyer. Never send a full dataset before price; practitioners advise a manifest and samples.
Everything here is invented to show the sequence. A fictional firm of 14 people sees that Mode lists accounting firms with 10 or more employees and wonders whether it qualifies. Its systems hold eight years of client email, practice-management records, a document portal and a shared drive of procedures.
The partners map each system to their engagement letters. Older letters say nothing about third-party use; newer ones limit use of client information to performing the engagement. Their lawyer flags section 7216 for the tax side and advises against including any client correspondence, ledgers or returns. The portal and client email are excluded in full.
What remains is the firm's own: month-end close checklists, review procedures, onboarding guides for new staff, internal training recordings with client examples removed, and the anonymized workflow of how jobs move between preparer, reviewer and partner. The partners decide not to ask clients for permission, because the request itself could worry them. The scope is smaller than they hoped, and they accept that it may be worth less or may not interest a buyer at all.
That is a legitimate outcome. The checker and the programs' published rules tell you whether you fit; your client agreements tell you what you can actually offer.
An archive spans years of letters with different wording. The oldest records are governed by the oldest terms. Check each version that applies to the data in scope.
Scrubbing reduces what a buyer can see. It does not, by itself, answer whether you were allowed to disclose the material in the first place.
A full copy sent before scope and price are settled is already a disclosure. Send a manifest and cleared samples, as practitioners advise.
Client files contain personal data about people you have never dealt with. Privacy laws can apply to them even when the client relationship has ended.
Generic questions every seller should check. They are not claims about any named buyer. Our licensing agreement outline goes clause by clause.
Will you be asked to state that you have every right and consent needed to share? Can you say that for each source, today?
If a client claims a breach of confidence, who pays? Is liability capped, and does the indemnity expire?
Training only, or evaluation too? Can the data go to other buyers? A narrower scope is easier to defend to clients.
Can you review samples of the output before acceptance, to check that client details are gone?
When are originals and copies deleted? Your duties to clients survive the deal. Do the buyer's confidentiality duties to you survive termination?
If a client later objects, can you withdraw its material? Does exclusivity or resale language make that impossible?
There is no single answer. It depends on your contracts with customers, privacy laws such as CCPA/CPRA or GDPR, sector laws such as HIPAA or GLBA, and professional rules if you are a regulated firm. Customer personal data and client-confidential material are the hardest parts of any sale. Ask your lawyer which of your sources can be shared at all before you discuss price.
Mode publishes a minimum of 6 employees for law firms, so small firms can apply. But attorney-client privilege, work product and lawyers' confidentiality rules cover most matter files. What tends to remain after review is firm-owned process material such as templates, checklists and internal workflows, cleared by ethics counsel.
Not necessarily. A confidentiality duty usually covers information, not only names. A memo about an unannounced acquisition can reveal the deal even with every name replaced. Ask your lawyer whether de-identified content is still covered by your obligations to clients.
Check every engagement letter, NDA and master agreement that covers the data. Some forbid any disclosure, some allow it with consent, some are silent. Where permission is needed and you cannot get it in writing, leave that client's material out.
Mode publishes a minimum of 10 employees for accounting firms. Client ledgers, returns and correspondence carry client confidentiality duties, and tax preparers should ask a lawyer about Internal Revenue Code section 7216, which governs the use and disclosure of tax return information.
Silence is not permission. Professional rules, implied duties and privacy laws can still apply. Ask your lawyer how they read silent contracts before you treat any client's material as available.
You can, but weigh it first. A request for consent to license client material can worry a client even if you only want internal process data. If you ask, do it in writing, describe the scope and use precisely, and exclude every client who declines or does not reply. Your lawyer should confirm what form valid permission takes under your professional rules.
They are usually the easiest material to clear, because the firm wrote them for itself. Check them for embedded client examples, names, figures and copied client documents first. micro1 lists SOPs, knowledge bases and QA processes among what it wants, so this layer is in scope for at least one program.
The eligibility checker runs in your browser and sends nothing. It asks whether your data includes client-confidential records and points you to the right questions. Applying starts a review; it is not an offer.
Independent site. Some links are referral links: if your company signs with a buyer through them, the buyer may pay us a fee. You are not charged, and we never see your data.