# Who can license schedule exception records? | SourceX

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

Introduce the CEO, with HR and counsel involved, and bring in the workforce director as the convener. The workforce director knows which exception days were documented and where overrides were logged, so they are the right first contact, but schedules, adherence and time cards describe individual employees, and the person who runs the WFM tool is rarely the one who can say yes. Technical access to the platform is not authority. What can be licensed stays unknown until SourceX's rights review.

This decision tree is part of the [workforce schedule exceptions guide](/guides/workflow-workforce-schedule-exceptions). It answers one question for workforce management advisors: inside the client, who can authorize a conversation about schedule exception history?

## Access is not authority

Workforce management advisors often hold administrator rights to a client's WFM platform. They built the forecasting groups, configured the queues and know where override notes are stored. That makes them the best-informed outsider, and it makes it easy to mistake the WFM administrator for the decision-maker.

Workforce data is closer to people than most operational data. A forecast is about the business, but a schedule names who works when, an adherence score measures one agent, and a time card is a payroll record. Where EU law applies, the GDPR defines personal data as any information relating to an identified or identifiable person, including by reference to a name or an identification number; an agent ID on a schedule fits. That does not rule the records out. It decides who must be in the room.

## Who can say yes: the tree in five questions

Work down in order. Each answer names the next person. The graphic draws the same tree, from the system administrator at the top to the signer at the bottom.

1. **Who do you know?** If it is the WFM administrator or an analyst, ask who decides how exception days are handled and reviewed. The answer is usually the workforce director or WFM manager.
2. **Will the workforce director convene?** Ask whether they would sponsor an internal conversation about the company's exception history. If yes, they become your working contact. If no, stop; nobody else will carry it.
3. **Whose operation is it?** If the company runs its own contact center, continue. If it is an outsourcer staffing a client's program, the services agreement may give the client a say over program schedules and volumes. Note it and continue; the outsourcer's own methods may still be in scope.
4. **Do employee records come into scope?** Schedules, adherence and time cards do. HR and counsel decide what employee data may be used beyond running the operation, under which notices, and in what de-identified form.
5. **Who approves?** The CEO, or the owner-CEO in an owner-run company. The COO or CFO may sponsor the case internally. Where a parent company or investor holds approval rights over company information, add them.

Stop when you have a convener and a named approver. That pair is the introduction.

## Each record class and its decider

| Record class | Who can describe it | Who decides about licensing it |
|---|---|---|
| Forecasts and reforecast versions | WFM analyst | CEO |
| Override requests, reason codes and approvals | Workforce director | CEO, with HR where agents are named |
| Schedules and adherence by agent | WFM manager | HR and counsel, then the approver |
| Service level by interval and queue | Head of customer operations | CEO |
| Incident and release tickets | Product or engineering lead | The product owner, then the approver |
| Overtime approvals and time cards | HR and payroll | HR and counsel, then the CEO |
| Program schedules at an outsourcer | Outsourcer's operations lead | Often the client, under the services agreement |

Retention duties are a separate question from licensing. In the U.S., employers covered by the FLSA must keep time cards and work time schedules for at least two years under 29 CFR 516.6. That rule tells HR what must be kept. It says nothing about whether any record may be licensed, which is why HR and counsel appear in the right-hand column rather than the WFM team.

## Where the tree needs HR, counsel or another owner

Three side branches change scope without ending the conversation:

- **Small or long-tenured teams.** De-identification is harder when a handful of people can be recognized from shift patterns alone. The [re-identification risk answer](/questions/re-identification-risk-small-workforce) explains why, and HR should hear about it early.
- **Employee representatives.** Where the company has a union or other employee representatives, HR will know whether they need to be informed. Note that the question exists; do not answer it.
- **Outsourced programs.** If a client owns the program, its schedules and volumes may be out of reach without that client. The [business process outsourcing page](/industries/business-process-outsourcing) covers outsourcer contracts.

None of these is a reason to skip the introduction. They are reasons to tell SourceX early, in the [referral brief template](/resources/workforce-schedule-exceptions-referral-brief-template), so the review starts in the right place. If the relationship itself worries you, read [whether an introduction can hurt a client relationship](/questions/does-referring-clients-hurt-relationship).

## What stays unknown until the rights review

When the CEO agrees to talk, four questions remain open, and none of them is the partner's to answer:

- **Rights:** which record classes, queues and years the company can license after employee, privacy and client checks.
- **Form:** whether override records travel with agent identifiers removed, aggregated by team, or not at all.
- **Demand:** whether any buyer wants schedule exception histories when SourceX reviews them.
- **Terms:** whether an offer follows, and on what payout and schedule.

The [records across systems map](/guides/workforce-schedule-exceptions-records-across-systems) shows the convener what to describe, and [why data rights matter](/proof/why-data-rights-matter) explains why the rights review comes first. The [introducer guide to operational data licensing](/guides/a-business-introducer-guide-to-operational-data-licensing) covers the wider process.

The introduced 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, and one partner is credited per company.

## 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 workforce director has agreed to convene and to bring in the CEO, who can say yes, with HR aware, [register as a partner](/register), confirm the company on [who qualifies](/who-qualifies) and read the [program terms](/terms) before making the introduction.

## Sources

- https://refer.sourcex.si/terms
- https://www.ecfr.gov/current/title-29/subtitle-B/chapter-V/subchapter-A/part-516/subpart-A/section-516.6
- https://eur-lex.europa.eu/eli/reg/2016/679/oj/eng