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Joint privacy-authority study connects data governance with valuation and deal diligence

CNIL, ICO and CNPD examine how privacy, data quality and governance affect data-asset value and transaction risk.

Joint study by authorities in France, United Kingdom and Luxembourg
Data discovery, governance, M&A diligence, accounting and AI readiness
Guidance
Official source reviewed

PrivacyBuilt Editorial · Source published Joint research study and emerging practices · Reviewed 20 October 2026 · 6 min read

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The 60-second summary

A joint study announced on 16 October 2026 examines privacy and data governance in valuation, accounting and transactions. It links data-related opportunities with associated compliance and operational risks. The study's emerging practices have no legal effect. Its practical relevance is to make data assumptions testable before they support financial or AI decisions.

Timeline that matters

  1. 16 October 2026

  2. October 2026

  3. 27 October 2026

What changed

A new joint study brings privacy into data-asset and transaction discussions.It provides emerging practices, not a mandatory valuation method.

Who should care

M&A and investment diligence teamsFinance and accounting specialistsPrivacy and data-governance leadersAI project and data-product owners

Why this matters for global organisations.

A dataset's usefulness depends on more than its size. Validate provenance, permitted uses, quality, retention and security before relying on it in a transaction, valuation or AI project.

13 actions to start now

  1. Inventory material datasets and their business owners.
  2. Document intended uses and underlying business assumptions.
  3. Trace provenance and contractual restrictions.
  4. Assess lawful processing and reuse with counsel.
  5. Test representative data quality and completeness.
  6. Identify excessive retention and sensitive-data concentrations.
  7. Review security and access evidence.
  8. Map suppliers, transfers and dependency risks.
  9. Provide diligence reviewers with proportionate, protected evidence.
  10. Record remediation costs and uncertainties separately from valuation judgments.
  11. Ask accounting specialists to assess recognition and measurement criteria.
  12. Challenge unsupported claims that more data necessarily means more value.
  13. Retain approvals and revisit assumptions after material changes.

Evidence worth retaining

  • Data-asset inventory and provenance
  • Purpose and reuse assessments
  • Quality tests and retention decisions
  • Security and supplier assurance
  • Diligence questions and controlled disclosures
  • Remediation estimates and uncertainty register
  • Qualified valuation/accounting reviews

Questions to take to counsel or your conformity team

These are discussion prompts, not legal advice or conclusions.

  • Can the proposed use be supported legally and contractually?
  • Which data assumptions drive expected benefits?
  • What gaps change the transaction's risk assessment?
  • What can be disclosed safely during diligence?
  • Which accounting conclusions require independent specialist judgment?

Official sources

PrivacyBuilt / PrivacyBuilt is an independent educational publisher. It is not affiliated with, or endorsed by, any regulator or the European Union.

PrivacyBuilt publishes educational and technical guidance. Nothing on this site constitutes legal advice, and it should not be relied on as a legal determination for your organisation.

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