Chapter 05 of 08
The Offering · Vol. 02 No. 01
The Room · 05
September 2026 · London
KYC, the travel rule, and who is actually your customer · Data
Identity data is not a marketing asset
Passports in a Notion board are a breach waiting for a date.
Purchaser KYC data is high-risk personal data. It needs a controller, a purpose, a notice, a vendor with a contract, access control, retention, and a deletion story. It does not need to live next to the claims register. Mixing comms and KYC is how a contractor sees passports. Contractors seeing passports is how you write to a data commissioner as well as a financial one.
Product waitlists collect the minimum. Offering processes, if they exist, collect what the process legally requires, on rails designed for it. Do not pre-collect “so we’re ready.” Readiness is a programme, not a Dropbox.