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FranceEmployee data in an insolvency: what has to stay out
Employee and HR records are the most sensitive part of company data. Why they are usually left out of any licence, and how to separate them.
Every company's records contain people. Most of the value for AI developers is in how work was done, not in who did it, so the safest licences leave personal data out.
Why employee data is different
HR files hold contracts, pay, performance, health and disciplinary records. Employees did not choose to share them, and data protection laws in every country micro1 lists protect them. They are usually excluded entirely.
How to separate it
- Exclude whole systems: HR, payroll and benefits platforms stay out.
- Filter channels: leave out HR, people and private channels in Slack or Teams.
- De-identify the rest: names, emails and phone numbers in tickets and documents are removed or replaced before any sample.
- Check consent and notice: ask your adviser whether employees must be told.
Customers and payments
The same applies to customer personal data, payment card and bank details, and any health, children's or biometric data: remove, de-identify or exclude.
Use the readiness checklist to work through it, then run the fit check.
