Short answer: Carefully. Tickets and documentation describe client environments and often include credentials and personal data, and clients covered by the FTC Safeguards Rule must require safeguards from service providers by contract. Expect to strip credentials, get client consent where contracts require it, and focus on your own processes.
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Your clients' obligations flow to you
Covered financial institutions must oversee service providers by selecting capable providers, 'requiring your service providers by contract to implement and maintain such safeguards', and assessing them periodically (16 CFR 314.4(f)). Many MSP contracts carry those terms.
What to remove
- Passwords, keys and tokens in tickets and documentation.
- Client end-user personal data.
- Network diagrams and security configurations.
What's valuable and yours
Ticket workflows (triage, escalation, resolution) and runbooks are outcome-rich records. Mode names four drivers: how many people work in the company's systems (today and at its peak), years of records, number of connected systems, and volume. Records that show outcomes, such as deals won or lost and jobs completed, raise the number (Mode affiliate FAQ).
This is general information, not legal advice. Talk to your own attorney or compliance advisor before you share or license any records.
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Frequently asked questions
Can we license PSA data if client names are removed?
Check client contracts first; many restrict use of client data to providing services.
Does Mode treat MSPs as software?
Mode's 50+ rule covers industries outside legal, accounting, medical and finance.
Sources
- 16 CFR § 314.4, Safeguards Rule elements (Cornell LII)law.cornell.edu
- Mode affiliate FAQ (PDF, dated Oct 14, 2026)bizbuydata.com
- Mode / BizBuyData referral pagebizbuydata.com
Referral-fee disclosure: we may be paid by a program if your company signs with it after using this site. General information only, not legal advice.
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