# Who can license store transfer records? | SourceX

Canonical: https://refer.sourcex.si/questions/who-can-license-store-transfer-discrepancies-records
Last updated: 2026-10-19

Start with the head of inventory operations, then ask them to name the owner of each system and to bring in the CEO, who can approve a licensing discussion. The inventory lead knows where variances are worked, how reason codes are used and roughly how many cases a year there are, so they are the best first contact and usual sponsor. They seldom hold authority over employee data, customer data or licensing; that rests with the CEO, with counsel.

This answer belongs to the [store transfer discrepancies hub](/guides/workflow-store-transfer-discrepancies). The [system map](/guides/store-transfer-discrepancies-records-across-systems) shows where scans, receipts and adjustments sit; this page answers who can say yes.

## Follow the branches, left to right

Each step is a question you can ask the person you already know, without seeing a single scan or receipt.

1. **Who works store transfer variances day to day?**
   - The head of inventory operations, or an inventory control manager: first contact and likely sponsor. Go to 2.
   - Nobody owns it centrally: ask the COO's office who would know; the absence of an owner is itself a coverage answer.
2. **Which systems hold the records, and who administers each?**
   - Warehouse system and scan data: the distribution center manager.
   - POS and store receiving: the retail operations or store systems lead, who also knows what happens to data when a store closes.
   - Adjustments and write-offs: the finance controller.
   - Each of these confirms coverage. None of them, by role alone, can approve a licensing discussion. Go to 3.
3. **Is anyone offering access in place of authority?**
   - A consultant running a store consolidation, an IT contractor or a system administrator may hold every login. Access is not authority; thank them for the system answers and go to 4.
4. **Do the records name people?**
   - Almost always. Scan logs carry picker and receiving associate IDs; adjustments carry approver names; some stores record customer details on returns or special orders. Under the EU General Data Protection Regulation, Article 4(1), information relating to a person identifiable by a name or an identification number is personal data. The legal or privacy lead decides what limits apply. Go to 5.
5. **Who decides whether to open a licensing discussion at all?**
   - The CEO (in an owner-run retailer, usually the owner), often with the CFO preparing the case. In a Delaware corporation, for example, business is managed by or under the direction of the board, and the CEO acts within that authority. The CEO is the signer. Go to 6.
6. **What stays open until SourceX's rights review?**
   - Treatment of employee IDs, any customer data, which stores and years could be included, and whether any buyer wants the records. Introduce the signer with these listed as open.

## Role by role at a multi-store retailer

| Role | What they can tell you | Authority to approve a licensing discussion |
|---|---|---|
| Head of inventory operations | Workflow, volumes, reason codes, years of history | Sponsor; not the signer |
| Distribution center manager | Warehouse configuration, scan levels, retention of scan logs | No; confirms the shipping side |
| Retail operations or store systems lead | POS receiving, store closures, local records | No; confirms the receiving side |
| Finance controller | Adjustments, write-offs, shrink reporting | No; confirms finance records |
| Legal or privacy lead | Employee and customer data limits | Must review; advises |
| CFO | Financial records and policy | No; prepares the case with the CEO |
| CEO (often the owner) | Whether to open the discussion | Yes; authorizes and signs |
| Outside consultant or contractor with logins | System detail | No |

## When ownership changes: acquisitions, banners and consolidations

Store transfer histories often span a change of owner: a chain folded into another banner, stores closed and merged, an ERP replaced after a deal. Each raises the same question, which legal entity holds the records now.

- **Acquired chain.** The acquired company's records may still sit in its old systems under its own entity. Ask deal counsel which entity holds title before naming a signer.
- **Consolidation into one platform.** The UK regulator's data sharing code says merger due diligence should seek technical advice where different systems are involved, and after the merger check accuracy and apply a consistent retention policy. The same review tells the company which history it still holds and on what terms.
- **Sponsor-owned retailer.** A fund's operating partner may need to be consulted; the [operating partner meeting prep resource](/resources/mcp/mcp-operating-partner-meeting-prep) shows how those conversations are usually framed.

## Three illustrative endings

Illustrative and fictional.

| Retailer | Path | Where it ends |
|---|---|---|
| A 410-person apparel chain, founder-owned | Inventory head sponsors; own warehouse and POS; employee IDs in scans | Introduce the owner with outside counsel; IDs flagged for review |
| A 650-person grocery group after buying a smaller chain | Old chain's scans in a separate system under the acquired entity | Deal counsel confirms title first; CEO of the parent becomes signer |
| A 180-person specialty retailer mid-consolidation | Consultant holds admin logins and offers to "pull everything" | Decline; ask the COO to bring in the CEO; no records leave the company |

## Before you make the introduction

The signer should hear four things: which record classes exist (transfer orders, scans, receipts, cases, adjustments), roughly how many years, that scan logs and adjustments name employees, and that the partner has seen none of it. The [store transfer referral brief](/resources/store-transfer-discrepancies-referral-brief-template) puts those answers on one page; [why data rights matter](/proof/why-data-rights-matter) explains why the authorizing person comes before any record review. If you are advising the retailer on a live project, read [introducing a third party during an engagement](/guides/consultant-introduce-third-party-during-engagement) first, and see [wholesale distribution](/industries/wholesale-distribution-data-monetization) for neighboring record types.

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.

## 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 branches end at a named executive and the inventory head has agreed to sponsor, [register as a partner](/register), confirm the retailer against [who qualifies](/who-qualifies), and read the [program terms](/terms) before you make the introduction.

## Sources

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