We have several companies or brands. How does that work?

Each company licenses the records it owns, and a brand belongs to whichever company trades under it. Match every system to the company that holds it, sort out shared accounts and shared staff, then have each owning company sign, in one agreement or several.

Is each brand a separate company?

Only if it was formed as one. The SBA describes a “doing business as” name as a way to “conduct business under a different identity from your own personal name or your formal business entity name”, so a brand run as a DBA is a name one company trades under, and its records sit in that company’s accounts and contracts.

Separately formed companies stay separate even when the same people own them all. In Dole Food Co. v. Patrickson (2003), the Supreme Court said a corporate parent that owns a subsidiary’s shares “does not, for that reason alone, own or have legal title to the assets of the subsidiary”. Start with a list of legal entities, then put each brand under the company that runs it.

Which company owns which records?

The company whose name is on each software account is the starting point, not the whole answer, because shared accounts, shared staff and intercompany services can put one company’s records in another company’s systems. Map each system to the company that holds the account and the companies whose staff and customers appear in it. Records a company holds for its own clients are a separate question, covered in Is it legal?.

Setup	The question to settle	Where the answer is
Each company has its own accounts: its own Microsoft 365 or Google tenant, QuickBooks file, field-service account	Whose name is on each subscription	Subscription and billing records
One tenant serves several brands	Whose staff wrote which mailboxes	The mailbox and domain list. Microsoft says a subscription can typically hold up to 5,000 domains and host “any of the services, such as email, on any of the domains you add” (updated May 6, 2026)
One company employs the office staff, or runs bookkeeping, IT or dispatch for the others	Whether the records it keeps are its own or held for the companies it serves	The intercompany services agreement, if there is one
A holding company sits above operating companies	Which records the holding company itself creates, such as board, finance and treasury files	Its own systems; the subsidiaries’ records stay with them
One company was bought	What the purchase transferred	We acquired a company

Take a hypothetical group of two HVAC companies and a service company that employs the dispatchers and pays for one Microsoft 365 tenant with both domains. Each HVAC company’s field-service account is in its own name. The dispatchers’ mailboxes sit in the service company’s tenant but record work for both, and who owns the shared books depends on the intercompany agreement. Where there is no written agreement, the question goes to your lawyer before any export.

Who signs?

Each company whose records are in scope, or someone that company has authorized. Authority runs company by company. Each company’s own agreement or bylaws, lenders and co-owners decide its part, so a co-owner of one company may need to agree for that company’s records and have no say over the others’. Providers ask about that authority in their own words; My partners or board need to approve quotes them and lists the documents to read for each company.

One license or several?

Either can work. The choice turns on how tangled the records are and whether the companies might part ways.

Structure	Fits when	Watch for
One agreement, with each owning company as a party	Records are intertwined, through a shared tenant or shared staff, and one buyer takes them all	That the agreement lists each company’s records, exclusions and share of the payment
A separate license per company	A company may be sold on its own, or has different co-owners or lenders	Assignment and change-of-control terms in each; see licensing, then selling the business
One company only	The others hold client or regulated records, or their owners have not agreed	Shared systems that mix in the other companies’ records

If a license is exclusive, check whether the grant covers only the signing company’s records or also those of its affiliates. Selling or licensing? explains exclusivity.

Do provider size floors count the whole group?

None of the providers that publish one says. As of October 5, 2026, nine providers give an employee figure for the companies they look for, and none of their pages says whether it counts one company or the group:

Provider	Published figure
Corpus	“25+ employees” on its checklist; “We license from companies with 30+ people.” on its form
Handshake AI	“20+ full time employees & 3+ years in operation”
idler	“10-100 employees”, on its Y Combinator profile
License My Data	“30 to 200+ employees” for operational knowledge; “100+ employees” for workplace records (source)
micro1	“30+ employees”
Miro Advisory	“Roughly 20–700 employees”
Nyne	“20+ full-time U.S. W-2 employees”
Scale AI	“40+ employees is our preferred starting point”, assessed case by case
Telegraph Lab (affiliated with Data Licensing Report)	“20+ employees”, on its referral page

Two of them mention groups. License My Data’s list of the businesses it looks for ends “and above all holding companies and portfolio groups”, and micro1’s payout estimator asks “How many business entities does your company have?”, meaning “Distinct businesses under your company, including subsidiaries”. Ask each provider which count it uses, and give both.

Some privacy laws look at the group:

• Texas exempts businesses that are small “as defined by the United States Small Business Administration” (§541.002), apart from a consent rule for selling sensitive data. The SBA counts the employees or receipts of a company “and all of its domestic and foreign affiliates” (13 CFR 121.103(a)(6)), and BakerHostetler’s March 11, 2024 analysis of the Texas act applies that to its employee test: “the average number of people employed by a business (plus its domestic and foreign affiliates)”.
• California’s act reaches an entity that controls or is controlled by a covered business “and that shares common branding with the business and with whom the business shares consumers’ personal information”. Common branding means a shared name, service mark or trademark that the average consumer would take as a sign of common ownership (Civil Code §1798.140(d)(2)).

Which of your companies those laws reach is for your lawyer; Is it legal? covers what each act requires.

What do we put on the application?

The application has one company name, so use the other fields to describe the group:

Field	What to enter
Company name	The company whose records you would license; if several, the parent or main company
What your company does	Each company and brand, what it does, and which brands are separate companies
People at your company	The headcount of the companies whose records would be in scope; give the group total in the description if it differs
Software and how far back it goes	Each system with the company that holds it, such as “Microsoft 365, one tenant for all three”
Other places you operate	Where every company in scope operates; for UK or EU companies, see UK and EU operations
Could you export these records if asked?	The answer for the systems in scope. If another company in the group or an IT firm controls a shared account, pick the option that fits and say so in the description

What do I do next?

1. List the legal entities, then the brands under each.
2. Put every system on the list under the company that holds the account, noting which other companies’ staff use it.
3. Find the intercompany agreements, and note where none exists.
4. Settle approvals company by company with each company’s documents.
5. Make one inventory with a column for the owning company, and run each company’s exports through the sample tool on their own so each package covers one company.
6. Apply once, describing the group as above, and decide on one license or several when proposals arrive.