Realising data assets in liquidation and administration: a service for UK office-holders

This page describes what we do and deliver on a case. The law and practice, from powers of sale to the ICO's data sharing code and SIP 9, are in our office-holder guide. Nothing here is legal advice: take advice from an insolvency solicitor on each case.

What we do in the first week of an appointment

We help you stop the deletion clocks before anyone values the records. Unpaid cloud accounts are downgraded or deleted on fixed timetables, admin logins leave with former staff, and privacy notices vanish when websites go offline. Slack, for example, downgrades an unpaid workspace to its free subscription at 28 days¹⁰, and an ended Microsoft 365 subscription passes through Expired and Disabled stages before its data is deleted¹¹.

In the first week we help you list every system and who pays for it, keep critical subscriptions paid, take one admin login per system, record retention settings and export to UK storage with a chain of custody log. We also collect every version of the privacy notice, customer terms and staff handbook, because the ICO's code asks you to identify the purposes for which data was originally obtained³. The result is the preservation plan, the first document for your case file.

The day-by-day checklist and each provider's timetable are in the guide: how to preserve data in the first 14 days.

What we deliver for the case file

Seven documents, each written for the case file and your report to creditors. Together they follow the steps the ICO's code sets for a sale of data on insolvency³.

The realisation assessment is not an independent valuation. We are not valuers, and because we are paid only if a licence completes, we have an interest in a sale; where the estate needs an independent valuation, instruct a valuer. Your solicitor approves the licence; we do not give legal advice. The guide explains how operational data is valued for the estate, and our valuation page sets out how we estimate value.

How we handle personal data on a case

We prefer personal data to be removed before any records leave the company's systems, either inside those systems or by a UK processor under contract to the company. Where a buyer removes personal data after transfer, we tell you in writing first, and your solicitor approves the transfer route before anything moves.

The ICO's code says that on insolvency "data might be sold as an asset", and that "you might be an insolvency practitioner or other adviser taking the role of controller for the time being"³. Regulators have also warned insolvency practitioners before: in 2020 the FCA, ICO and FSCS said some had tried to sell clients' personal data to claims management companies unlawfully⁴. So the route, the exclusions and the test applied are recorded in the lawful basis and de-identification note.

Our standard is on our anonymisation page, and the wider legal position is in our UK law guide. The guide works through what the ICO data sharing code requires on an insolvency sale.

How we document a best-value sale

By approaching more than one buyer, comparing offers on more than price, and recording every step in the buyer marketing record. The Insolvency Code of Ethics lists disclosure of "the process undertaken to evaluate best value and service" among the safeguards for referral and agency arrangements⁶.

1. Shortlist the buyers whose published criteria the company meets, dated. Our buyers page keeps that comparison. We ask each buyer to confirm in writing that it accepts UK companies before we introduce the company.
2. Run each buyer's own process with the company, acting by its office-holder. micro1, for example, requires the company to register through its own process, and manual introductions do not replace that¹².
3. Compare more than price: de-identification route, exclusivity, acceptance window, payment timing and certainty.
4. Record every approach, response and reason.

Prices are uncertain: buyers "quote wildly different numbers", one told MIT Technology Review¹³. The best-known precedent is Google's winning USD 10 million bid for Spirit Airlines' data in a US bankruptcy¹³; the sale still awaits court approval, with a hearing set for 17 November 2026¹⁴. It shows real competition for an insolvent company's records, but sets no UK precedent and no price for a smaller company. The guide covers running a sale that shows best value, including exclusivity and connected parties.

What our fee disclosure note contains

Who pays us, how much, when and on what conditions. The estate pays nothing: when a licence completes, the buyer pays us an introduction or referral fee, and we give you the note in writing before the company signs any licence, so it can be reported to creditors.

• The fee and who pays it. Each buyer's published reward, with the date checked. micro1's page, checked on 12 November 2026, shows USD 75,000 for defunct-company deals up to USD 1 million, then 7.5% above that, paid only after the data is transferred and approved¹². A third-party report says new defunct-company referrals move to USD 50,000 terms from 8 November 2026, except applications made by 7 November¹⁶. We ask micro1 to confirm in writing which terms apply, and the note gives the confirmed figure. Other buyers' rewards are on our fees page.
• Who else receives any part of it. The Insolvency Code of Ethics bars the practitioner, the firm or an associate from accepting referral fees during an appointment unless they are paid into the estate and disclosed to creditors (R2340.7)⁶. SIP 9 treats as an associate anyone a reasonable and informed third party might consider one⁵. The note states whether anyone other than Sleeping Asset receives any part of our fee.
• Why we were recommended. The Code requires the reasons for recommending a particular provider to be documented (R2330.10)⁶. The buyer marketing record supplies them.
• Effect on the price. Creditors may ask whether a buyer-paid fee reduced the price to the estate. Buyers do not publish whether it does, and the note says so.

How SIP 9 applies, and the questions creditors are likely to ask, are set out in the guide: how SIP 9 applies to fees.

Working alongside asset agents and insolvency solicitors

We add a specialist route to AI buyers; we do not replace your agent or your solicitor. Asset agents already sell UK intangibles: in the 2019 Loot Financial Services administration, Hilco Streambank marketed software, brand, a customer database and domains, and used a "non-exclusive-licensing and purchase structure" to complete deals with several parties⁹.

The Code of Ethics expects you to consider a third party's fitness for purpose and its professional or regulatory status⁶. Sleeping Asset is a trading name of Augustova Ltd, registered in England and Wales and with the ICO. We are not insolvency practitioners or a law firm, and we take no appointments. Sleeping Asset launched in November 2026 and has no completed cases yet. See about us.

Which cases are worth assessing?

Cases where the company had 20 or more staff, several years of records in cloud tools, mostly in English, and admin access that can still be secured. A 30-minute call is usually enough to tell.

• Good signs: peak headcount of 20 or more (micro1's defunct programme asks for 30 or more and English-language data¹²); several years of records in Microsoft 365, Google Workspace, Slack, a ticketing tool, a CRM or code repositories; records about the company's own operations; systems still reachable.
• Weaker cases: a short trading history, archives that are mostly HR or health records, client files held in confidence, or systems already deleted.

In 2025, 2,520 businesses with 20 to 249 employees entered insolvency in England and Wales: 1,540 creditors' voluntary liquidations, 570 administrations, 320 compulsory liquidations and 85 other procedures, in rounded counts⁷. There were 1,882 company insolvencies in September 2026 alone⁸. Our analysis of the UK company data licensing market puts these figures in context. Scotland and Northern Ireland differ in places; see the guide.

Directors closing a solvent company should read closing a company.

Book a 30-minute case call. It is free and confidential, and we reply within one working day.