Suggested coordination effort: 3–8 internal person-days plus scoped counsel review; remediation duration unknown. Ask counsel to interpret actual source agreements for the proposed use and components. US copyright law separates ownership of a copy from ownership of copyright; a file inventory therefore cannot settle the licensing question. US Copyright Office — Title 17, Chapter 2: Copyright Ownership and Transfer
Keep the assessment limited to what will actually be released. Exclude unresolved cohorts while investigating them separately. Check privacy notices, confidential material and contractual duties as well as copyright. The FTC's historical Everalbum order illustrates that data-use problems can lead to model-related remedies; it is not a general permission or prohibition for all business datasets. FTC — Everalbum: final decision and order, 7 May 2021
Prepare a release sheet specifying recipient, authorised staff and processors, purpose, sample version, delivery method, duration, prohibited reuse, retention and closure evidence. Legal, security and commercial reviewers should see the same sheet. Obtain an evaluation agreement appropriate to the task; this guide does not provide executable legal clauses.
Who to contact: IP counsel, the privacy lead, security, and the buyer's accountable technical owner. Completion condition: authorised reviewers approve the bounded sample and the recipient accepts the evaluation terms. An urgent deadline or high quiz score does not override a missing release approval.