Someone asked me recently what’s the status of a customer logo in relation to data. Specifically, if a SaaS provider stores customer logos in their system – for example, for white labelling the customer’s login screens for staff – do those logos need to be treated as customer data or can they be treated as public domain data?

First, it’s highly unlikely the customer logo is in the public domain. For a logo to have any value, it must identify the customer and distinguish them from their competitors. As such, the logo will have been created by or for the customer who will likely own the rights to it. The SaaS provider will need a licence to use it – yes, even for providing the white label service back to the customer. The contract or SaaS terms should cover that.