# Service recovery records: who can say yes? | SourceX

Canonical: https://refer.sourcex.si/questions/who-can-license-service-recovery-approvals-records
Last updated: 2026-10-19

The guest operations director, or the director of rooms, is the right first contact: they run service recovery, know which promises turned into disputes and know where threads, service requests and folio credits sit. They do not approve a licensing discussion; the CEO does. Structure decides whose consent is also needed: the owner's when a management agreement governs the records, and the brand's terms for a franchised property. Privacy counsel joins early, because guest messages are personal data, and the final answer waits for SourceX's rights review.

This page belongs to the [service recovery approvals guide](/guides/workflow-service-recovery-approvals). It answers one question with a tree: who can say yes for a hotel company, and whose agreement has to be checked before that yes counts.

## First fork: who operates the hotel?

Hotel groups split ownership and operation in ways most other businesses do not. Settle this fork before anything else, because it changes who holds the records.

| Structure | Who usually controls guest and operating records | Likely signer | Extra party to expect |
|---|---|---|---|
| Owner-operated group | The operating company | CEO (often the owner) | Privacy counsel |
| Managed hotel | Depends on the management agreement; often shared between operator and owner | Operator's CEO | Owner's consent; privacy counsel |
| Franchised property | The franchisee for its own systems; the brand for brand-run platforms | Franchisee's CEO (often the owner) | Brand standards and platform terms; privacy counsel |
| Mixed portfolio | Varies hotel by hotel | Group CEO | A list of which hotels sit in which structure |

For the general question of shared systems, see [who owns data in a shared group system](/questions/who-owns-data-in-a-shared-group-system). After an acquisition, access and ownership can diverge further; [recovering admin access after an acquisition](/guides/recover-admin-access-after-acquisition) covers that case.

## The tree, node by node

1. **Sponsor.** Guest operations director or director of rooms. Confirms that conflicting promises happen, that threads and folio credits exist, and roughly how many years back.
2. **Structure.** Owner-operated, managed, franchised or mixed, as above.
3. **Platform ownership.** Does the hotel company hold the messaging and property system contracts, or does a brand or owner? Messaging administrators can say what exists and how far back. That is access, not authority.
4. **Privacy branch.** Counsel or the privacy lead joins on every path; see the next section.
5. **Signer.** The executive named for that structure agrees to a first call.
6. **End: SourceX rights review.** What could be licensed, what must be removed, and whether the structure allows it at all are decided here, not by the partner.

## Guest communications: the branch counsel always joins

Every path through the tree passes privacy counsel, for a simple reason. Under the GDPR, personal data is any information relating to an identified or identifiable person, including by a name or an identification number. A guest thread holds a name, a room number, a phone number and whatever the guest wrote. Property records add more: OPERA Cloud service requests, for example, are linked to a profile, reservation or room and record which staff member closed them.

The European Data Protection Board lists purpose limitation, data minimization and storage limitation among the GDPR's core principles, and says controllers must be able to demonstrate compliance. For a hotel company with EU guests, that means a licensing discussion turns on what de-identification and which purposes the privacy lead can stand behind. A partner should never suggest keeping or copying guest messages to preserve them; that decision belongs to the company.

## Who knows, who decides: roles at a hotel group

- **Guest operations director or director of rooms.** Knows the recovery process and the disputes. Sponsor, not signer.
- **General manager of a property.** Knows that hotel's cases; usually cannot commit group records.
- **Messaging administrator or IT.** Knows retention settings and exports. No authority to license.
- **Front office manager.** Knows how service requests and reason codes are used. Facts only.
- **Privacy lead or counsel.** Decides what guest data could ever be used and on what terms. Can narrow or stop the discussion.
- **Group CEO (often the owner).** Decides whether to explore licensing and signs, subject to owner or brand agreements on the records.

How approval limits shape exception records in other functions is covered in [procurement approvals and exception workflows](/guides/how-to-assess-procurement-approvals-and-exception-workflows); the same idea explains why a front desk agent's offer and a director's decision carry different weight in these records.

## Still open after the tree

- **Agreement wording.** Whether a management or franchise agreement lets the operator license operating records is a legal reading.
- **Brand platforms.** Thread history held on a brand-run tool may not be the hotel's to offer.
- **De-identification.** What would be removed from threads and folios before any use.
- **Demand and terms.** Buyer interest, which records are selected and any offer are unknown until SourceX reviews them. The [complaint handling records page](/data-types/complaint-handling-records) explains what typically stays out of scope.

SourceX licenses approved business data directly from companies for AI training and evaluation, and manages the agreement, rights review, data preparation, delivery and payout.

## Pre-introduction check for CX consultants

- **Sponsor willing.** The guest operations director will raise the idea internally.
- **Structure known.** You can name which branch of the first fork applies, or that it is mixed.
- **Signer named.** The CEO has agreed to a first call, or the sponsor will ask.
- **Company fits.** 50+ full-time employees at peak (contractors excluded), a documented operating history, rights to license the records 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.

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. The [system map for these records](/guides/service-recovery-approvals-records-across-systems) helps the sponsor describe coverage, the [referral brief template](/resources/service-recovery-approvals-referral-brief-template) gives you the note, and consultants new to the program can start at the [CX consultant referral program](/for/cx-consultant-referral-program). More hotel workflows are on the [hospitality page](/industries/hospitality).

## 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 signer and the hotel structure is clear, [register as a partner](/register), confirm the company against [who qualifies](/who-qualifies), and read the [program terms](/terms) before you make the introduction.

## Sources

- https://docs.oracle.com/en/industries/hospitality/opera-cloud/24.1/ocsuh/t_managing_profiles_service_requests.htm
- https://eur-lex.europa.eu/eli/reg/2016/679/oj
- https://www.edpb.europa.eu/topics/key-gdpr-concepts/basic-principles_en
- https://refer.sourcex.si/terms