Accountants, lawyers, consultants and other trusted advisers are often the first to notice that a client might hold records an AI data buyer would value. That position comes with responsibilities. A client trusts you to put their interests first, to keep their affairs confidential and to be open about anything that might influence what you suggest. This guide sets out how to handle an introduction in a way that respects all three.
It is general guidance, not a statement of your professional obligations. Your own regulator’s rules and your engagement terms always come first.
Start with the client’s interests
Before you mention licensing, ask whether it could genuinely suit the client. A business that is short of time, in the middle of a transaction or sensitive about confidentiality may be better off not exploring it at all. Suggesting an opportunity is fine. Pressing a client towards it because a reward might follow is not.
Be clear about what you are offering. You are pointing out that some AI data buyers license historical records and that the client might qualify. You are not offering a valuation, promising acceptance or advising that licensing is right for them, unless that advice is within your competence and your engagement.
Keep the client’s information confidential
Confidentiality applies before the client has agreed to anything. Do not share the client’s name, records or any identifying details with ADP or a buyer until the client has given written consent. That includes informal conversations: a description such as a sixty-person engineering firm in a named town may be enough to identify a client.
If the client decides to explore licensing, they share records directly with the buyer under their own agreement. Neither you nor ADP should act as a channel for the data. ADP has no upload facility and will never ask for exports, documents or passwords.
Disclose any referral interest, in writing
If you might receive a referral reward from a buyer, tell the client before they decide. Explain who would pay it, how it is calculated where the buyer publishes that, and that it is not guaranteed. Then let the client decide with that knowledge.
Professional rules point the same way:
- The SRA Code of Conduct for Solicitors requires solicitors to tell clients about any financial or other interest they have in referring them to another person, and to put any fee-sharing arrangement in writing.
- The ICAEW Code of Ethics recognises that referral fees and commissions can create a self-interest threat to objectivity, and describes safeguards such as agreeing commission arrangements with the client in advance.
- Other professional bodies have their own rules. Check the current version of yours before you make an introduction.
ADP’s process records the fee disclosure before the client’s written consent, so the order of events is always clear.
Get written consent before naming the client
Written consent should cover, in plain language:
- that the client agrees to be introduced to ADP and, later, to a named buyer;
- what information you will share, typically contact details and basic facts about the business;
- that you have disclosed any referral interest you have;
- that the client can change their mind at any point before signing anything with a buyer.
Keep a copy. ADP will not record an introduction until consent and the fee disclosure are in place, and approved partners see only their own referrals.
Stay independent
Your value to the client comes from your independence. Protect it:
- Do not represent the buyer. You are not the buyer’s agent or spokesperson. At least one buyer’s referral terms prohibit referrers from presenting themselves as its employee, agent or representative.
- Do not share rewards with the client’s people. Some buyer terms prohibit offering or sharing any part of a referral reward with the referred company, its owners, employees or representatives. Never use a reward as an inducement.
- Recommend independent advice. Encourage the client to take legal and data protection advice on any licence, from someone with no interest in the outcome.
- Leave the decision to the client. The client decides whether to apply, what to include and whether to sign.
Use the correct route to the buyer
Buyers credit introductions under their own rules. Typically the company must register through the introducer’s official link, and an existing registration may not be reassigned later. Agree the route with the client before they register, and never register a client yourself without their authority.
At ADP, approved partners on the Direct track use their own buyer referral link, and any reward is paid to them by the buyer under its terms. A managed arrangement, in which ADP would share a reward with a partner, is not offered: it would need the buyer’s written permission and a signed agreement.
Keep a record
A short file note for each introduction protects you and the client. Record when you raised the opportunity, what you disclosed, when consent was given, what you shared and with whom, and the decisions the client made. If a question arises later, you will have a clear answer.
Know when to step back
Sometimes the right answer is not to make the introduction at all. Step back, or suggest the client takes separate advice, if:
- you would be advising the client on the licence itself while also standing to receive a referral reward;
- the client relies on you heavily and may find it hard to say no to your suggestion;
- the records include material you hold under a duty of confidence from your own work for the client;
- you are not confident you can explain the opportunity, and its risks, accurately.
Where to start
Read our page for advisers and the safeguards we apply. If you want the full picture, including how the market works, how to qualify a business, consent, compliance and the buyer programmes in detail, the ADP info pack is a course written for advisers. To see whether a particular client might fit, use the business check, which asks only general questions and no client names. Our article on referral rewards explains the payment side.
Frequently asked questions
Can I mention the opportunity to a client before getting consent?
Yes. Raising the idea is fine. What needs written consent is sharing the client’s name or details with ADP or a buyer.
Do I have to tell the client about a referral reward?
You should disclose any referral interest before the client decides, and many professional rules require it. ADP records the disclosure before the client’s consent.
Can I share part of my reward with the client?
Not without checking the buyer’s terms first. At least one buyer prohibits sharing a referral reward with the referred company, its owners, employees or representatives.
Is a reward guaranteed if my client signs a licence?
No. Buyers pay referral rewards only under their own programme rules, usually after the deal completes and the data is accepted. An introduction can end without any reward.