Decision record
It manages money without being allowed to hold any
The surprising constraint was that the platform could not behave like a bank simply because it manages financial workflows. Member funds remain with approved banks and licensed payment providers; the platform records operations, accounting, approvals and evidence without claiming a banking or payment licence. That boundary changed the architecture. Consequential actions need immutable audit records. Financial writes and outbox events commit together. NDPA obligations — lawful basis, retention, data-subject rights, processor records, a DPIA — are part of the platform design rather than a policy bolted on. Staging is production-shaped and contains no real member data.