# Who can license special pricing records? | SourceX

Canonical: https://refer.sourcex.si/questions/who-can-license-special-pricing-agreement-exceptions-records
Last updated: 2026-10-19

Introduce the pricing director first, then expect the CEO, with counsel, to decide. The pricing director runs the request and approval process and knows where approvals, claims and rejections are kept, which makes them the best guide and usual sponsor. Licensing authority sits higher, because special pricing records are shaped by supplier program agreements and name end customers. Some questions stay open until SourceX's rights review.

This answer belongs to the [special pricing agreement exceptions hub](/guides/workflow-special-pricing-agreement-exceptions). The [system map](/guides/special-pricing-agreement-exceptions-records-across-systems) shows where the records sit; this page answers one question: who can say yes.

## Walk the tree from first contact to signer

Start with whoever you already know at the distributor. Every node is a question you can ask without seeing a quote, letter or claim.

1. **Does this person run special pricing requests and claims day to day?**
   - Yes: they are your first contact and likely sponsor. Go to 2.
   - No: ask who does. In most distributors that is the pricing director or pricing manager; start there.
2. **Do they hold authority over the company's commercial records, or only access to the tools?**
   - Access only (CPQ administrator, inside sales, claims clerk): useful for coverage questions, never for approval. Go to 3.
   - They are also the CEO, as in some founder-run distributors: they are the signer. Go to 4.
3. **Who owns supplier relationships and data policy?**
   - Supplier programs usually sit with the vice president of purchasing or the COO; financial records with the CFO; confidentiality with counsel; the final say, and the signature, with the CEO, often the owner. In a Delaware corporation, for example, the business is managed by or under the direction of the board, and the CEO acts within that authority. Go to 4.
4. **Does the operating company hold the records outright?**
   - Yes, in its own CPQ and ERP: go to 5.
   - A buying group or a parent company runs the pricing platform: ownership is "to confirm" until counsel reads that arrangement.
   - The business is being sold: go to the sale branch below before introducing anyone.
5. **Do supplier program agreements restrict disclosure?**
   - They can, and nobody should assume either way. A supplier's special price and approval letter are the distributor's records, but they sit under the supplier's program agreement. Counsel reads the agreements; the partner only notes that they exist. Go to 6.
6. **Do approvals or claims name end customers or individuals?**
   - Usually: approvals name projects, contractors and sometimes site contacts. Under the EU General Data Protection Regulation, Article 4(1), any information relating to an identified or identifiable person is personal data. Rights review decides what is removed or de-identified. Go to 7.
7. **What is left that only the rights review can settle?**
   - Always: supplier consent, end customer de-identification, which years and suppliers could be included, and whether any buyer wants the records. Introduce the signer with these listed as open.

## Who holds what at a distributor

| Role | What they know | Can they authorize a licensing discussion? |
|---|---|---|
| CPQ administrator | Quote configuration, exports, user rights | No: access, not authority |
| Inside sales or branch manager | How quotes are copied and reused | No |
| Claims accountant or rebate analyst | Claim submissions, rejections, credits | No, but confirms what finance holds |
| Pricing director | The whole request, approval and claim process | Sponsor and first contact, not the signer |
| Vice president of purchasing | Supplier program agreements and relationships | Often a required voice; does not sign |
| CFO or COO | Financial records, supplier terms, company risk | Prepares the case; does not sign |
| General counsel or outside counsel | Confidentiality terms, data policy | Must review; advises |
| CEO (often the owner) | Overall authority over company records | Yes; authorizes and signs |

Technical access is never authority. The CPQ administrator who can export every quote in minutes cannot agree to a licensing discussion, and neither can a consultant who holds admin rights during a pricing project.

## Where supplier, customer and buyer rights enter

**Suppliers.** Special prices and approval letters are commercially sensitive to the supplier as well as the distributor. The question on [distributor supplier price file confidentiality](/questions/distributor-supplier-price-file-confidentiality) explains why counsel reads program terms before anything moves. This is a "to confirm" item, not a reason to stop.

**End customers and contractors.** Project names, contractor accounts and named site contacts appear throughout. Most of the business value is in the pattern (approval, order, rejection, repair), not the identity, which is why de-identification is usually discussed early. [Why data rights matter](/proof/why-data-rights-matter) sets out how SourceX approaches this.

**Acquirers and lenders.** If the company is in a sale process, title to records and any limits on them can surface in the purchase agreement; see [special indemnities in M&A](/questions/special-indemnity-m). The UK regulator's data sharing code says merger due diligence should identify the purposes for which personal data was originally collected and the lawful basis for sharing it, which is the same question a licensing review asks. Where a lender is involved in a workout, the [special assets group page](/for/special-assets-group-bank-workout) covers who else may need to be told.

## Three illustrative paths through the tree

Illustrative and fictional. These show how the same tree ends in different places.

| Distributor | Path through the tree | Outcome |
|---|---|---|
| A 340-person plumbing and HVAC distributor, founder-owned | Pricing director runs claims; COO owns supplier programs; own CPQ and ERP; program agreements with confidentiality clauses | Introduce the founder-CEO with the COO and counsel; pricing director as sponsor; supplier terms flagged for review |
| A 520-person electrical distributor owned by a fund | Pricing manager sponsors; CFO owns records; board approval needed for new data agreements | Introduce the CEO, who takes it to the board; nothing promised on timing |
| A 210-person building materials dealer being sold | Records sit in the operating subsidiary; buyer due diligence under way | Ask deal counsel which entity holds title and whether the sale agreement limits use; introduce only once confirmed |

Lumber and building materials deals raise the same ownership questions; the [lumber yard acquisition page](/industries/lumber-yard-acquisition) gives that context.

## What the signer needs to hear, and what stays unknown

Before the introduction, the signer should know four things: which record classes exist (requests, approvals with dates, order lines, claims and rejections), roughly how many years, where supplier terms might apply, and that the partner has seen none of it. The [referral brief template](/resources/special-pricing-agreement-exceptions-referral-brief-template) puts those answers on one page.

The company needs 50+ full-time employees at peak (contractors excluded), 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. 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.

Unknown until SourceX's rights review: supplier consent, de-identification of end customers, buyer interest and any offer.

## 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.

Once the tree ends at a named executive and the pricing director has agreed to sponsor, [register as a partner](/register), confirm the distributor against [who qualifies](/who-qualifies), and read the [program terms](/terms) before you make the introduction.

## Sources

- https://refer.sourcex.si/terms
- https://delcode.delaware.gov/title8/title8.pdf
- https://eur-lex.europa.eu/eli/reg/2016/679/oj/eng
- https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/data-sharing/data-sharing-a-code-of-practice/due-diligence/