# Who can license placement dispute records? | SourceX

Canonical: https://refer.sourcex.si/questions/who-can-license-placement-guarantee-disputes-records
Last updated: 2026-10-19

Start with the operations director, who usually signs off placement guarantee decisions and knows where the memos, claims and credit notes sit. That person sponsors; the approval to open a licensing discussion comes from the CEO (in an owner-run firm, the owner), often with the CFO preparing the case. Admin rights in the ATS are access, not authority. Counsel reads the client agreements for confidentiality terms, and the placed candidates' details raise privacy questions that stay open until SourceX's rights review.

This answer is part of the [placement guarantee hub](/guides/workflow-placement-guarantee-disputes). It does one job: get a staffing software consultant from the person they already know to the person who can say yes.

## Why ATS admin rights are not a yes

Staffing software consultants usually meet the people who configure the ATS: the back office manager, a systems administrator, a placement coordinator. They can run any report and see every placement, which makes them feel like the right contact. They are not. Seeing the records and having the authority to commit them are different things, and an introduction built on an administrator's enthusiasm tends to stop at the first executive who hears about it.

Use administrators for what they know well (which years have change requests, whether claims are tagged, how credits are booked) and keep looking for the approver.

## Six questions from first contact to signer

1. **Who decides disputed placement guarantee claims today?**
   - The operations director, in many firms: start there as sponsor. Go to 2.
   - Account managers decide alone: ask who reviews their decisions, and start with that person.
2. **Is the sponsor also the CEO or owner?**
   - No: go to 3.
   - Yes, in an owner-run firm: they are also the approver. Go to 4.
3. **Who holds that authority?**
   - The CEO, who in an owner-run firm is the owner, usually with the CFO preparing the case because credit notes, refunds and client terms run through finance. The CEO is the approver. Go to 4.
   - A private equity-backed firm: the portfolio company CEO, with the fund's board as a possible extra step.
4. **Do client agreements restrict use of dispute records?**
   - Counsel has read them and confidentiality terms can be met by removing client details: go to 5.
   - Not yet read: mark "to confirm"; you can still introduce the approver with this listed first.
5. **Do the records identify placed candidates?**
   - Almost always, as they stand. Names, start dates and resignation reasons are personal data. Go to 6 with counsel involved.
6. **What stays for the rights review?**
   - Client consent, de-identification, buyer interest and any offer. Introduce the approver with these written down as open.

## Who in a staffing firm holds which piece

| Role | What they hold or know | Can they authorize a licensing discussion? |
|---|---|---|
| Placement coordinator or back office | Change requests, start-date corrections, placement fields | No |
| ATS administrator | Reports, tags, data structure | No: access only |
| Recruiters | Call notes, role-change emails | No |
| Head of account management | Claim cases, client correspondence, which clients restrict reuse | No, but flags client limits |
| Operations director | Decision memos, how disputes were weighed | Sponsor; rarely final |
| CFO or controller | Credit notes, refunds, how they were booked | No; prepares the case with the CEO |
| CEO (often the owner) | Client relationships and overall appetite | Yes; authorizes and signs |
| Counsel | Client agreement terms, candidate privacy | Advises; may set conditions |

## Client contracts and candidate privacy: the two sign-off branches

**Client agreements.** The guarantee clause sits inside a contract with the client, and client correspondence often carries confidentiality terms. That does not usually make the client the owner of the firm's own decision records, but it does mean counsel must read the terms before anything leaves the firm. The head of account management knows which clients negotiated tighter clauses, so ask early.

**Candidate data.** Every dispute record names the person who was placed and often says why they left. Under the EU GDPR, Article 4(1) defines personal data as any information relating to an identified or identifiable natural person, including by name or identification number; equivalent rules apply in other jurisdictions. The [candidate data ownership answer](/questions/who-owns-candidate-data-staffing-agency) explains how ownership and privacy layer for staffing firms.

Keep one more distinction clear. A legal duty to keep records is not permission to license them. U.S. employers covered by EEOC rules must keep personnel or employment records for one year from the record or the personnel action, and longer while a discrimination charge is pending, under 29 CFR 1602.14. That duty says nothing about secondary use, and it is not a reason to keep anything longer.

## Paths through the tree at three firms (Illustrative)

Fictional examples, written for this page.

| Firm | Path | Where it ends |
|---|---|---|
| A 210-person IT staffing firm, founder-led | Operations director sponsors; founder-CEO approves, with the CFO preparing the case; counsel reads the top 20 client agreements | Introduce the CEO and CFO together, client terms and candidate data listed as open |
| A 350-person healthcare staffing firm owned by a fund | Sponsor's authority is process only; portfolio CEO approves; board informed | Introduce the portfolio CEO; board step noted in the brief |
| A 120-person firm being sold | Seller and buyer both involved; records may move with the sale | Wait until deal counsel says which entity will hold the records; see [selling a staffing company](/guides/selling-a-staffing-company) |

## What only SourceX's rights review can settle

For SourceX, an introduced company needs 50+ full-time employees at peak (contractors excluded), a documented operating history, rights to license and an authorized contact. Companies in the U.S., Canada and the EU qualify, as do companies in the UK, Australia, New Zealand, India, Singapore, South Africa, Latin America, the UAE and Saudi Arabia when at least 90% of the data is in English.

Whoever signs, these remain open until review: whether client consent is needed, what de-identification requires, whether buyers want this record type and whether any offer follows. [Why data rights matter](/proof/why-data-rights-matter) explains why the review comes before anything else. Partners sign the Channel Partner Agreement before submitting introductions; the first valid introduction within the 90-day window is credited when the company submits a verified application. If the firm also asks about fees for referring its own clients, [staffing agency client referral fees](/questions/staffing-agency-client-referral-fee) is a separate topic. To understand which records the approver would be asked about, read the [placement guarantee system map](/guides/placement-guarantee-disputes-records-across-systems); to hand the answers over, use the [placement guarantee brief](/resources/placement-guarantee-disputes-referral-brief-template) template.

## Next step

> **Refer a company. Earn up to $100,000.** Default reward: 25% of Actual Supplier Payout, capped at $100,000 cumulatively per referred company. Eligibility and payment conditions apply, and a signed Schedule A or addendum can differ. A lead, meeting or signature alone does not trigger payment.

When the tree ends at a named CEO or owner and the operations director has agreed to sponsor, [register as a partner](/register), check the firm against [who qualifies](/who-qualifies) and read the [program terms](/terms) before making the introduction.

## Sources

- https://eur-lex.europa.eu/eli/reg/2016/679/oj/eng
- https://www.ecfr.gov/current/title-29/subtitle-B/chapter-XIV/part-1602/subpart-C/section-1602.14
- https://refer.sourcex.si/terms