Data Governance — Woodfine Corporate

Woodfine Management Corp. is the legal custodian of all property ledger data, investor records, and operational data generated in connection with WMC-managed assets. PointSav Digital Systems processes data as a contracted technology services provider under the technology services agreement; PointSav does not hold independent data rights over any WMC-custodied data. The custody arrangement implements the Fiduciary Data Mandate within the broader vendor-customer model.

[edit]Key takeaways

WMC is the legal data custodian for all property ledger records, investor identity data, and transaction history; PointSav acts as a data processor under WMC's instructions and holds no independent data rights.
Operational data is segregated at the asset level — an investor in one Direct-Hold asset cannot access the records of a different asset, and no administrative override can grant cross-asset access without a structural ledger change.
WMC can request a full data export at any time under the portability obligation, preserving its ability to change technology providers without losing operational history.

[edit]Data custodian

The legal custodian of a data set is the entity with the right and responsibility to determine how it is stored, used, and ultimately destroyed. WMC is the legal custodian for all property ledger records, investor identity data, transaction history, and operational records generated by WMC-managed assets.

PointSav processes this data under the technology services agreement, acting as a data processor rather than a data controller in the sense that WMC's instructions govern how data is handled. PointSav does not independently use, share, or retain WMC-custodied data beyond the scope of the services agreement.

[edit]Personal information

Investor identity data and contact information are collected under the Personal Information Protection and Electronic Documents Act (PIPEDA). WMC's privacy notice governs the collection, use, and retention of personal information. Personal data is not sold or transferred to third parties except where required by a legal obligation — such as anti-money-laundering reporting under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA).

Investor identity records are retained for the period required by applicable securities law and anti-money-laundering legislation. Following the required retention period, records are destroyed pursuant to WMC's data retention schedule.

[edit]Operational data segregation

Asset-level operational data — financial events, occupancy records, maintenance history — is segregated by asset. An investor in one Direct-Hold asset cannot access the operational data or position records of a different asset. This segregation is a property of the ledger architecture: access controls are enforced at the asset level, not at the portfolio level. No policy exception or administrative override can grant cross-asset data access without a structural change to the ledger.

[edit]Data portability

WMC's data governance framework requires that all ledger data be exportable in standard formats. The portability requirement is imposed on PointSav under the technology services agreement. WMC can request a full data export at any time; PointSav is obligated to deliver the export in a format WMC can read and operate independently of PointSav's software platform.

Portability is the mechanism by which WMC maintains the option to change technology providers without losing the operational history or equity record of any asset.

[edit]Retention

Property ledger records are retained for the duration of the asset's operational life plus the period required by applicable securities law. Financial event records are append-only during the asset's operational life; no prior record is overwritten or deleted. At the end of the required retention period following asset disposition, records are destroyed pursuant to WMC's data retention schedule and applicable destruction standards.

[edit]The bottom line

WMC's data governance framework allocates custodian responsibilities clearly and enforces them through both legal obligation and ledger architecture. WMC holds the data; PointSav processes it. Personal information is collected and retained only to the extent required by PIPEDA and applicable anti-money-laundering legislation. Asset-level data segregation is a structural property of the ledger — not a policy that can be waived. The portability requirement ensures that WMC's ability to serve investors is never contingent on its current technology provider's continued cooperation.

[edit]See also

Fiduciary Data Mandate — the governance obligations WMC holds as custodian of the property ledger
Property Ledger Technology — the technical infrastructure on which ledger data is stored and maintained
Vendor-Customer Model — the services relationship that governs PointSav's role as data processor