The fund's role is narrow on purpose. It holds shares, not the archive, and what it knows about a company's systems usually arrived through board packs or information rights. SourceX's screening guidance treats that knowledge as a reason to ask the CEO, never as material to pass along.
Why a purge reaches the fund before anyone has weighed licensing
Deletions rarely announce themselves as decisions about history. They show up as a line in a board pack about storage costs, a vendor contract the company has chosen not to renew, a cleanup after an acquisition or a refreshed retention policy. Each is framed as a cost or a risk question, and none of them asks whether the records have value beyond the company.
That is the gap an operations lead can close with a question, and only a question. The schedule, the systems and the duties belong to the company. If the company has since been acquired, the acquirer's CEO decides for it, and the fund may no longer have a path at all. SourceX's note on legacy archives in holding groups makes the same point from the security side: storage can be pooled, ownership stays with the entity that collected the records.
Pin down the archive, the entity that holds it and the person who answers for it
Before any rung, collect six facts, all from the company and all descriptive:
- the system or vendor that holds the archive, and whether it is a live system, a backup or an export;
- the years it covers and a rough volume;
- the legal entity whose records they are (not the fund, a holding vehicle or a brand name);
- who administers retention: a records manager, an IT lead or general counsel;
- the scheduled deletion date and what triggers it, such as a contract end or a policy run;
- the current CEO, and since when.
None of these needs a file, a sample or a login. If the CEO prefers that someone else answers, that person is the CEO's choice. The company's own pre-deletion review is a separate job, and the four-gate disposal checklist is written for the CFO or IT provider who runs it; the ladder below is only what the fund asks.
The retention-owner escalation checklist
Five rungs, climbed in order. The company answers each one; the fund's part is in the last column.
| Rung | Ask | Who answers | The ladder stops when | The fund's part |
|---|---|---|---|---|
| 1. Scope and date | Which records, in which systems and entity, deleted on what date? | The CEO, or the person the CEO names | The records are already gone, or there is no date yet | Note the date; if they are gone, see what can still be recovered |
| 2. Retention owner | Who owns the retention schedule and approved this deletion? | The records manager, IT lead or general counsel the CEO names | Nobody owns it, which is for the CEO to fix, not the fund | Ask the CEO to name an owner |
| 3. Duties to keep | Does a hold, a pending claim or a legal minimum require keeping any of these records? | Counsel | A hold applies: those records stay preserved for that purpose, outside any licensing talk | None; counsel's matter |
| 4. Duties to delete | Does a law, a policy or a customer contract require some records to go? | Counsel and the privacy lead | Deletion is required: it proceeds on schedule | None; never ask for a delay |
| 5. CEO's choice | With both duties mapped, does the CEO want SourceX to look at the company's own remaining records before the date? | The CEO | The CEO says no or not now | If yes, the relationship holder shares a partner link and the company applies itself |
Rung 1 can end the ladder honestly. If the archive went last quarter, read what can still be recovered after archives are deleted before raising anything.
Rungs 3 and 4 face opposite directions, and one archive can trigger both. On the keep side, the EEOC's recordkeeping rules generally require private employers to hold personnel and employment records for one year from the record or the personnel action, whichever is later, and once a discrimination charge is filed, the relevant records must be kept until the charge reaches final disposition. A routine retention clock can stretch without warning. On the delete side, the European Data Protection Board's guidance for small businesses says personal data should be deleted or anonymised once it is no longer needed for its purpose, while national law can require some records, such as tax records, to be kept longer.
Sorting which records sit on which side is counsel's work, not the fund's. One rule holds throughout: a licensing review is never a reason to keep records that a law, policy or contract says must go. For how retention duties and licensing interact once the duties are known, see licensing records under a retention requirement, and for the wind-down version of the same tension, litigation hold versus data destruction.
Custody, control and the introduction on one deletion timeline (Illustrative)
Illustrative. A 180-person portfolio company plans to retire a helpdesk archive covering 2012 to 2021. Read each column on its own: custody is where the records sit, control is who decides, and the introduction is a separate decision that may never happen.
| Day | Event | Custody | Control | Introduction decision |
|---|---|---|---|---|
| Day -90 | A board pack mentions retiring the archive to cut storage costs | The company, on a vendor's storage | The CEO | None yet; the operations lead notes the date |
| Day -80 | The operations lead asks the CEO the rung 1 and 2 questions | Unchanged | The CEO names the IT lead as retention owner | None |
| Day -60 | Counsel reports no holds; customer personal data past its retention period will go on schedule | Unchanged | The CEO | None |
| Day -45 | The CEO asks for a SourceX look at internal runbooks, QA reviews and knowledge-base history the policy keeps | Unchanged | The CEO | The board member who holds the CEO relationship shares a partner link |
| Day -40 | The company applies | Unchanged; no files leave | The CEO | SourceX reviews; the outcome is unknown |
| Day 0 | Records that must go are deleted as planned | Narrows to what the policy keeps | The CEO | Continues only for what remains, if SourceX and the CEO proceed |
Custody never passes to the fund, and control never leaves the CEO. The deletion still happens on Day 0. What changed is that the CEO decided about the remaining records with the duties already known, instead of discovering the question after the purge. For a system that is being switched off rather than an archive being purged, the three-track system retirement timeline covers the cutover milestones.
A second Illustrative archive ends differently. A 140-person portfolio company plans to purge a recruiting and HR archive. Counsel finds a pending discrimination charge, so the related personnel records stay on hold, and applicant data past its retention period is deleted as policy requires. What remains is mostly about people, not about how the company operates, and the CEO sees nothing worth a review. The ladder stops at rung 5, and that is a good result: nobody argued with a duty, and nobody pushed the CEO.
Choosing an introduction window before the purge, or stopping
The window opens once rung 4 is answered and closes on the deletion date. That date is the only urgency worth citing, because it is documented; a quarter-end or a fundraising update is not.
Stop, and record why, when:
- the CEO declines or does not answer;
- the remaining records belong to the company's clients rather than the company;
- every record in scope must be preserved for a hold or deleted under a duty;
- the company has been acquired and nobody at the fund has a live relationship with the acquirer's CEO;
- the company is in a formal process, where the CEO alone may not be enough.
If the CEO says yes, whoever submits must have signed the SourceX Channel Partner Agreement, and the fund should agree internally, before anyone writes, whether the board member or the platform team is the partner of record. Credit then follows the terms, and section 2 sets the rule in one line: "The first valid introduction of a new company within the 90-day attribution window receives credit when that company submits a verified application." Section 3 adds that "Companies that already have an application, relationship or earlier valid introduction with SourceX are reviewed as duplicates and are not credited to a later partner." The portfolio side of the program is set out for venture platform teams.
Risks that could make this checklist the wrong move
- Legal duties outrank interest. Keep and delete duties come first, and a company that keeps personal data longer than it may is worse off, whatever a review might find.
- Demand moves. SourceX's criteria differ by program and relevance to current data needs is checked in review, so an archive kept for a review can still be declined.
- Rights. Helpdesk and CRM archives can mix the company's own work with customer content, and client-owned material is usually not a fit.
- Cost and exposure. Holding an archive longer costs money and widens what a breach could reach. That trade-off is the company's to make.
- Confidentiality and goodwill. A fund that repeats what it learned in a board pack, or leans on a CEO, can breach a duty and spend trust the checklist cannot measure.
Methods note. The five rungs are built from SourceX's published screening guidance and program terms, checked 2026-10-27, with the EEOC and EDPB pages as examples of duties that keep or remove records. Not measured: how often archives are deleted before anyone asks, how many CEOs choose a review or what any review produces. SourceX has not published those figures.
Next step
Refer a company. No cap on rewards. Default reward on a company's first qualifying transaction: the greater of $50,000 plus 5% and 15% of Actual Supplier Payout, with no cap; further qualifying transactions first agreed within 12 months of the first Closing pay 15%. Eligibility and payment conditions apply, including the USD 100,000 Minimum Transaction, and a signed Schedule A or addendum can differ. A lead, meeting or signature alone does not trigger payment.
If the duties are mapped and the CEO wants a look before the deletion date, register as a partner, check the company against who qualifies and read the program terms before the relationship holder shares a link. Guides on other portfolio transitions, from exits to system retirements, are listed in the guides hub.
Asking about a portfolio company's archive is referral work; anyone weighing SourceX itself as an investment can request materials through the SourceX investor overview.
This article is for information only and is not an offer to sell or a solicitation of an offer to buy securities. Any offering by SourceX is made only to verified accredited investors through its offering documents.