Document Management
Document management
1. DEUSS Core – Central Marketing Repository (for All Broker Platform Applications)
What Belongs in DEUSS Core (Marketing / Public Content)
- Issuance materials: term sheet, pitch deck, factsheet, investor presentation
- Marketing images/icons/logos, banners
- Public bond-related documents (provided they are not legally or AML-sensitive)
- Versioned documents for a specific bond / issuer / campaign
- Multi-language document variants
What Does NOT Belong in DEUSS Core (to Be Managed by the Distributor)
- Contracts and signed agreements
- KYC/AML attachments
- Personal data
- Audit trail evidence
- Transaction confirmations and statements
- Internal regulatory reporting
- Any content subject to “right to be forgotten”, retention requirements, legal hold, or regulatory preservation obligations
Documentation Rule DEUSS Core stores public/marketing content, while the Distributor stores regulated/legal/transactional evidence.
2. Implementation of DEUSS Core Document Storage
Storage Pattern
DEUSS Core document storage uses S3-compatible object storage (see Object Storage for infrastructure details). Metadata is stored in a relational database alongside the binary objects.
Example object key structure for marketing content:
marketing/{issuerId}/{bondId}/{locale}/{docType}/{version}/{filename}
API (minimal set)
POST /documents– Upload file + metadataGET /documents/{id}– Download or generate pre-signed URLGET /documents?bondId=&locale=&type=– Listing endpoint for frontendPUT /documents/{id}/metadata– Update tags, locale, visibilityPOST /documents/{id}/publish– Workflow transition (draft → published → archived)
Cache & CDN
Since marketing content (including icons, thumbnails, and listing visuals) will generate high traffic from marketplace applications, it is recommended to use a CDN (e.g., Cloudflare).
- Public documents may be served as static content via CDN
- Non-public documents should only be accessible via authorized API calls
Security & Access Control (Will Be Required?)
At minimum, document visibility levels should distinguish between:
- Public
- Partner-only
- Internal Access from Broker Platform frontend applications should be performed via OAuth2 token-based authentication, optionally combined with short-lived signed URLs. Audit logging should focus on administrative actions (upload, publish, delete), rather than logging every individual download (unless regulatory requirements demand it).
3. Broker Platform Application – Temporary Storage Only
Draft Application Data
Draft application data should:
- Be stored as draft state in the database
- Store binary files preferably in S3-compatible storage Implementation recommendations:
- Use a temporary bucket (or namespace) with TTL lifecycle policy (e.g., 72 hours)
- Mark files with attributes such as
draft=trueandexpiresAt - Implement automatic cleanup After completion of the application process:
- The draft is either transferred to the Distributor repository (where it becomes a regulated/legal document),
- Or it is discarded. Since this storage is strictly temporary, TTL enforcement and automated cleanup should be implemented to prevent unintended long-term persistence.
4. Distributor Application – Legal / Transactional Documents
Purpose
The Distributor Application is responsible for storing legally binding, regulatory, AML, and transaction-related documents. This repository represents the legally relevant system of record for documentation associated with:
- Issuer onboarding
- Investor onboarding
- Transaction execution
- Regulatory compliance
- Audit evidence Distributor bears responsibility for retention, compliance, and evidentiary integrity of stored documents.
Scope of Stored Documents
Distributor stores:
- Signed contracts (issuer agreements, investor agreements)
- KYC/KYB documentation
- AML reports and risk assessments
- Subscription agreements Optionally:
- Transaction confirmations
- Payment confirmations
- Regulatory reporting artifacts
- Audit trail exports
- Any document requiring retention under financial regulation These documents may contain personal data and regulated information.
Architecture
Storage Model
Distributor document storage uses S3-compatible object storage (see Object Storage). Metadata is stored in a relational database alongside binary objects.
- Document hash (SHA-256) stored for integrity verification
- Immutable audit log for:
- Upload
- Download
- Modification
- Access attempts Optional:
- Legal hold mechanism
- Retention period enforcement per jurisdiction
Security Requirements
Legal document storage must support:
- Encryption in transit (TLS)
- Encryption at rest (KMS or Vault-managed keys)
- Strict RBAC access control
- Segregation by jurisdiction (if required)
- Full audit logging
- Tamper-evident storage
- Backup & disaster recovery Access is never public. Downloads must be authenticated and authorized. Deletion must be auditable.
Integration: Responsibilities and Data Flow
DEUSS Core → Broker Platform Frontend
- CORE provides marketing content (document listing and download), CDN on Cloudflare should be enabled for that content.
- The Broker Platform application does not handle retention policies, legal hold, or AML-related document management.
Broker Platform → Distributor
- Submission of applications along with legal and transactional documents.
- Files should be uploaded directly to the Distributor’s storage (via pre-signed upload URLs).
- The Broker Platform application acts solely as an orchestration layer and does not persist regulated documents.
Document Governance & Classification “licence-ready” Model
To ensure regulatory clarity and operational separation of responsibilities, the DEUSS platform applies a formal document classification and governance framework.
- Retention Policy:
- DEUSS Core: marketing data - no retention obligation
- Broker Platform: Short-term retention only, documents stored solely during onboarding or bond creation processes.
- Distributor: Retention enforced according to applicable jurisdiction and regulatory framework.
- Versioning:
- Formal document versioning (DMS-style version control) is not initially implemented due to implementation complexity
- Access model:
- Access control is implemented according to document classification:
- DEUSS Core
- Public access for marketing content.
- Optionally served via CDN.
- Administrative actions (upload, publish, delete) are logged.
- Distributor
- Partner-only access.
- Strict authentication and authorization required.
- Administrative actions are audit-logged.
- Access to regulated documents is restricted to authorized roles only.
Business licence-ready Classification of Document model
| Area | DEUSS Core | Distributor |
|---|---|---|
| Marketing content | ✔ | — |
| Legal contracts | — | ✔ |
| AML documents | — | ✔ |
| Investor agreements | — | ✔ |
| Temporary draft uploads | — | (via Whitelabel → Distributor) |
| Retention enforcement | — | ✔ |
| Public document distribution | ✔ | — |