Data4U reference framework
Trust framework for data governance
The Data 4 U reference framework is above all a trust-based approach. In an environment where data has become a strategic lever, it establishes a clear framework so that data sharing and use are based on transparency, accountability, and shared values.
The ambition is simple: to create a trusted environment between public and private actors and citizens, built around data governance that is clear, operational, and sustainable.
Data 4 U is structured around three pillars, the three Cs: Consent, Control, and Compensation.
Consent is the guarantee that each party freely and knowingly commits to the use of data, whether personal or non-personal.
Control is the ability to monitor and manage uses over time.
Compensation, finally, is the recognition of the value created by sharing — whether economic, social, partnership-based, or environmental.
This framework is not a straitjacket; it is a starting point. It paves the way for more formal agreements, can serve as a basis for compliance audits, and will continue to evolve with technologies, regulation, and market needs.
Data 4 U is an agile, ethical, and unifying framework, serving trustworthy digital innovation and shared sovereignty.
Part I — Consent
Consent must be free, informed, and non-coercive. It concerns the sharing of data for a defined use over a specific period and gives entitlement to a clearly identified form of compensation. It must be accompanied by conditions related to the control of data.
1.1 — Free consent
Free consent means that each party has a real choice regarding the processing of its data, without pressure, constraint, or undue influence. Refusal to consent must not result in harm or restriction of access to a service when the processing is not necessary for the performance of a contract. For example, agreeing to receive commercial solicitations cannot be a condition for accessing a main service.
1.2 — Informed consent
Informed consent is based on clear, understandable and accessible information. The data subject must know the purposes of the processing, the nature of the data collected, the controller’s identity and their rights, in particular the right to withdraw at any time. Information must be specific and free from vague or generic wording so that people can make a truly autonomous decision.
1.3 — Non-coercive consent
Non-coercive consent excludes any form of threat, deception, intimidation or excessive incentive. Withdrawal must be easy and must not have negative consequences on ongoing services.
To demonstrate this, the data-using party must document: the information channels provided (clarity, accessibility, completeness); the absence of adverse consequences in case of refusal; and the reversibility of consent, ensuring it can be withdrawn at any time without detriment.
By way of illustration, the Data Governance Act promotes the concept of data altruism, which encourages stakeholders (companies, individuals, etc.) to share data they deem useful for the public interest.
These cumulative conditions guarantee freedom of choice and compliance with regulatory frameworks such as the GDPR, the French Data Protection Act, the Data Governance Act and the Data Act.
Part II — Control
Ongoing control of data over time is essential to build trust and verify that commitments between parties are respected, ensuring confidence and proper performance of contractual obligations around data sharing. It relies on several criteria that guarantee transparency, traceability, and quality of exchanges.
2.1 — Access
Each party has an effective and secure right of access to shared data, in line with contractually defined confidentiality obligations. Access rules and restrictions are set out in the data governance rules. Access logs and consultation histories provide evidence for traceability and compliance.
2.2 — Portability
Each party benefits from an effective right to data portability, enabling them to transfer, without restriction or alteration, the information they hold or have produced to any compatible technical environment. Data governance rules require the use of open, interoperable standards (...)
Interoperability ensures that data can be exchanged and used between different systems, services or platforms without technical barriers. It relies on open standards and coordinated, compatible formats enabling direct data transfer between entities.
2.3 — Interoperability
Interoperability ensures that data can be exchanged and used between different systems, services or platforms without technical barriers. It relies on open standards and coordinated, compatible formats enabling direct data transfer between entities.
2.4 — Quality
The quality of shared data is ensured through regular checks, audits, and the use of performance indicators (KPIs). These elements are documented in reports to demonstrate that shared data meets contractual requirements and to avoid disputes.
2.5 — Reliability
Reliability involves the use of control procedures, regular updating of information, and oversight of data sources.
2.6 — Authenticity
Authenticity is demonstrated through data integrity mechanisms such as electronic signatures, timestamps, or digital certificates.
2.7 — Security
Data security is ensured by technical and organizational measures (encryption, access control, backup protocols).
2.8 — Ethics
Ethical data sharing and control require transparency, fair practices, and respect for the rights of the parties and of the individuals concerned.
Ainsi, l’engagement contractuel sur le partage des données repose sur des critères précis, chacun pouvant faire l’objet d’une documentation ou d’une preuve opposable pour assurer la maîtrise du contrôle dans le temps.
Part III — Compensation
Any authorization to share data for a specific use must be accompanied by compensation that formalizes a balance between the parties and recognizes the value of the data exchanged.
Nature of the compensation
- Monetary: direct or indirect remuneration directly linked to the value of the data.
- Service-based: access to specific services offered in exchange for consent to share or use data.
- Benefits / valorisation: loyalty mechanisms, bonus/malus systems, perks, points, or other non-monetary incentives that encourage engagement and acceptance of data sharing.
The obligation of compensation is grounded in a logic of value creation linked to data exchange and sharing. It pursues a legitimate objective and runs counter to models that abusively reuse data.
The Data Act, which entered into force in 2025, reinforces this perspective by regulating data sharing between companies, by providing for fair and non-discriminatory conditions and allowing data holders to request reasonable compensation for making their data available.
This approach strengthens trust, encourages data sharing, and guarantees transparency in commercial or partnership relationships. To be valid, compensation must be clearly communicated, freely accepted, and its traceability ensured, without ever undermining the freedom of consent through coercion or disproportionate incentives.
Thus, compensation is a key lever that complements consent by establishing data sharing that is transparent, balanced, and aligned with the requirements of the European digital strategy.