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    IP & Data Ownership Checklist

    IP & Data Ownership: Standard Terms Clear boundaries for device IP, data custody, and FDA submission artifacts.

    Hero illustration for the article: IP & Data Ownership Checklist
    Christian Espinosa, Founder & CEO at Blue Goat Cyber

    By Christian Espinosa, MBA, CISSP

    Founder & CEO · Blue Goat Cyber

    Trevor Slattery, COO at Blue Goat Cyber

    Reviewed by Trevor Slattery

    COO · Blue Goat Cyber

    Last reviewed: May 1, 2026

    Free Guide · Blue Goat Cyber · Updated 2026

    CHECKLIST · 1 PAGE · PROSPECT RESOURCE

    IP & Data Ownership: Standard Terms Clear boundaries for device IP, data custody, and FDA submission artifacts.

    Cybersecurity engagements touch source code, threat models, and submission documents. This checklist is the baseline ownership model we recommend before legal review begins.

    Submission artifacts (always client-owned) Threat model, SPDF, cybersecurity risk assessment, and SBOM authored for your device. All FDA-facing deliverables and their underlying source data. Test reports and vulnerability findings tied to your product. Any code or configuration written specifically for your engagement.

    Tooling & methodology (consultant-owned, licensed for use) Proprietary scanning, fuzzing, and analysis frameworks. Internal templates, checklists, and review playbooks. Anonymised pattern data used to improve future engagements.

    Data handling & retention Data location, encryption, and access-control standards documented in the SOW. Defined retention period for FDA audit-support purposes. Clear deletion procedure once the retention window closes. Confidentiality terms for SBOM and VEX content beyond the engagement.

    How to read it. Any deviation from section one (client owns all submission artifacts) is a material risk and should trigger immediate legal review.

    NEXT STEP → Request our standard IP & data-ownership clause set to give your legal team a starting point that already reflects MedTech norms. Book your discovery call: go.bluegoatcyber.com/meetings/blue-goat-cyber/discovery-session

    Page 1 · © Blue Goat Cyber · 250+ FDA submissions, zero rejections, since 2014


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