What a fractional CFO may disclose about a client under a confidentiality agreement

Under a typical consulting NDA, a fractional CFO should treat even the client's name and the existence of the engagement as confidential unless the agreement says otherwise. For a SourceX introduction, get the owner's written permission first, then share only the company name, a size band and the sponsor's contact. Financials, records and system contents stay out.

The short answer: your NDA governs, and the owner's permission comes first

A fractional CFO may disclose only what the confidentiality agreement allows, and most consulting NDAs define confidential information broadly enough to cover the client's financials, systems and plans, and often the engagement itself. The safe rule for an introduction is simple: ask the owner first, share only what they approve, and never pass on records.

A SourceX introduction is designed to fit inside that rule. It needs the company's name, a rough size band and a sponsor contact the owner has agreed to share. It never needs financial statements, exports, screenshots or samples from you.

What typical NDA clauses mean for an introduction

ClauseWhat to readEffect on an introduction
Definition of confidential informationWhether it covers all non-public information, and whether the existence of the engagement is includedIf the engagement itself is confidential, even naming the client needs consent
Purpose or permitted useWhether information may be used only to perform the servicesA paid introduction may fall outside the purpose without consent
Permitted recipientsWhether disclosure is limited to your staff or representatives bound by similar dutiesA referral program is not your representative; treat it as a third party
ExclusionsInformation that is public, already known or independently developedA company's name and approximate size may be public; its records never are
Consent mechanicsWhether consent must be written and who can give itGet an email from someone with authority, not a verbal nod from a manager
Non-circumventionLimits on using the client's contacts or opportunities for your own benefitRead closely; some clauses reach introductions you would consider harmless
SurvivalHow long duties last after the engagement endsFormer clients usually remain covered

What SourceX needs from you, and what stays out

Share, with the owner's permissionNever share
Company name and websiteFinancial statements, forecasts, budgets or bank details
US location and whether it reached 50+ full-time employees at peak (contractors excluded)Customer, vendor or employee names and details
The sponsor's name, role and contact detailsExports, screenshots or samples from any system
How you know the companyCredentials, access or administrator details
Categories of systems in use, only if the owner agreesDebt terms, covenant positions, sale plans or disputes

The cleanest route avoids disclosure altogether: send the owner your referral link and let them apply at sourcex.si/apply themselves. Your referral code travels with the application, and the company decides what to tell SourceX. Before that, you can test fit privately with the company fit checker, which asks for no contact details.

How it applies in common situations

SituationWhat to checkSafe course
Current client with a broad NDADefinition, purpose clause and consent mechanicsWritten consent from the owner before you name the company
Former clientSurvival period and any non-circumvention clauseConsent from someone who can still authorize it
You subcontract through a fractional CFO firmThe firm's master agreement with the client and your agreement with the firmPermission from both the firm and the client
Sponsor-backed clientConfidentiality terms with the private equity sponsor as well as the companyThe sponsor's policy on third-party introductions
Client asks you to send sample data to test fitYour NDA, and the program rule that partners never handle recordsDecline; the company works directly with SourceX on its inventory
You hold a CPA licenseProfessional confidentiality duties on top of the contractYour state board's rules and your firm's policy

The second layer: what the client promised its own customers

Your NDA protects your client. Your client's privacy policies, terms of service and contracts protect its customers, and those promises limit what the company itself may license. In a January 2024 FTC staff post, FTC staff warned that when a company promises not to use customer data for undisclosed purposes, such as training AI models, that promise can be enforced, whether it sits in a privacy policy, terms of service or marketing materials. It is staff guidance rather than a rule, but it shows why that review matters. The review belongs to the company, its counsel and SourceX after the introduction; your role is to flag it, not to assess it.

What stricter professions do with client identity

Lawyers work under some of the tightest confidentiality rules, and their ethics opinions are a useful benchmark. The Illinois State Bar Association's Advisory Opinion 12-03 treats a client's identity as confidential and says client consent is needed before a lawyer shares a client's name in a networking referral arrangement. It does not bind CFOs, but it marks where a careful line sits: consent before naming.

A clean consent process

  1. Raise the idea with the owner in a regular meeting; the annual client advisory meeting agenda has a natural slot for it.
  2. Follow up by email stating exactly what you would share, with whom and why, and that you may receive a referral reward from SourceX.
  3. Get a written yes from someone with authority, and file it with the engagement records.
  4. Send your referral link, or submit only the approved fields through the referral form.
  5. Keep working papers, including any finance systems inventory you built for the engagement, inside the engagement. They are the client's information, not referral material.

Questions to ask your counsel

  • Does my NDA treat the existence of the engagement as confidential?
  • Is a paid introduction a permitted use of what I learned?
  • Does a non-circumvention clause cover introductions to service providers?
  • What form of consent does the agreement require, and from whom?
  • Do my professional rules require disclosure of referral compensation?

This is general information, not legal, tax or financial advice. Confirm with your own counsel, tax adviser or professional body before acting.

Next step

Read your standard NDA once with these clauses in mind, then adjust your consent email. When an owner says yes, register as a partner and send your referral link. The fractional CFO referral playbook covers which clients to consider first, and the CFO checklist for evaluating a data licensing agreement helps once the company decides to proceed.

  1. Step 1Share your linkSend your personal link to a company you know.
  2. Step 2Company appliesThe company applies itself at /apply.
  3. Step 3Buyer selects and paysThe buyer selects and pays for the data and SourceX receives its fee.
  4. Step 4You get your rewardYour share of SourceX fees becomes payable.

Common questions

Can I tell SourceX a client's name without asking first?

Treat the answer as no unless your agreement clearly allows it. Many consulting NDAs cover the existence of the engagement, and naming a client to a third party for a paid introduction sits outside the usual purpose clause. Ask the owner and get a written yes, or send them your referral link so they apply themselves.

Do I have to tell the client that I may earn a referral reward?

Disclosing it in writing is good practice for every advisor, and some professional rules require it in certain situations, so check yours. Put it in the consent email: who pays, that the reward is a share of SourceX's fee rather than a deduction from the company's proceeds, and that the client is free to decline.

Can I share a client's list of systems to check whether it qualifies?

Not without consent. Use the company fit checker, which needs no contact details, to form your own preliminary view. If the owner agrees to an introduction, category-level information such as which kinds of systems the company uses can be shared with permission. Exports, screenshots and record samples never come from the partner.

What if my NDA has a non-circumvention clause?

Read it closely. Non-circumvention clauses usually stop you from using the client's contacts or opportunities for your own benefit without consent, and a paid introduction can fall within that wording. Written consent from the owner normally addresses the concern, but counsel should confirm how your specific clause reads before you act.

Who protects the company's records after the introduction?

The company and SourceX, under their own agreements. De-identification and redaction requirements are agreed with the company before any work begins, and data is delivered only after an executed agreement and the company's authorization. The referring CFO is not part of the inventory, review or delivery and never receives copies of the records.

Free resources

By SourceX Partnerships Team · Published 2026-10-09 · Updated 2026-10-09

Know a US company with valuable proprietary data?

Become a referral partner from anywhere we support, get your link and introduce an owner or authorized decision-maker.

Refer a company →

I own a business

Explore licensing your company's data to AI developers worldwide. Start a short assessment; no uploads needed.

Start an assessment