Data Asset Foundation Services
Cavendish Trust provides the core services required to establish, register, and operate a Data Asset Foundation under the Isle of Man regime, with accreditation capability in active development.
Foundation Council
Every Data Asset Foundation is required to have a Foundation Council: the governing body with authority over the data asset itself. The Council approves utilisation decisions, oversees the Technical and Business Data Stewards, and appoints the Data Enforcer. It is the primary governance role within the regime.
Cavendish provides Foundation Council services as the lead component of its DAF offering. Council members bring the governance rigour, data domain awareness, and independence that the Handbook requires and that counterparties, regulators, and investors will expect to see in place.
Foundation Council
Registered Agent and Corporate Service Provider
Cavendish Trust can act as your Registered Agent for your Data Asset Foundation, the statutory role that manages your Foundation's administration and interface with the Data Asset Registrar.
We provide the full range of CSP services: Foundation establishment, constitutional documentation, register maintenance, compliance filings, and ongoing statutory administration throughout the life of the Foundation.
Registered Agent and Corporate Service Provider
Always provided together. Cavendish provides Foundation Council and Registered Agent services as an integrated appointment. Our Class 4 licence anchors the Foundation and our name sits on every filing, so we do not accept RA mandates for Foundations whose Council we do not hold. Clients with existing Council arrangements are welcome to discuss their structure with us.
Accredited Assurance Provider (AAP)
Full registration on the Isle of Man Data Asset Register requires an independent Accredited Assurance Provider to verify that the data asset meets the Isle of Man DAF Assurance standards. Cavendish Trust is actively building its AAP capability in parallel with the Isle of Man Government's development of the formal accreditation framework.
Our intended AAP offering will cover the full evidence-based review across Simplified, Standard, and Extended tiers, encompassing data governance documentation, capability and control verification, data protection compliance, and, for higher-sensitivity assets, independent verification of governance controls.
Our commitment: The Isle of Man Government has not yet published the final accreditation criteria for Accredited Assurance Providers under the Foundations (Amendment) Bill 2025. Cavendish Trust is committed to meeting those criteria in full as and when they are formally established. As an early participant in the regime's development, we are among the best-placed firms to achieve accreditation once criteria are confirmed. Enquiries regarding AAP services are welcome and we will be in a position to confirm our formal offering as the regime matures.
Accredited Assurance Provider (AAP)
Data Enforcer
Every Data Asset Foundation requires a Data Enforcer, an independent appointee with statutory oversight responsibility for the Foundation's compliance with its governing documents and the DAF governance framework. Cavendish Trust accepts Data Enforcer appointments.
The Data Enforcer role is distinct from the Registered Agent, the Foundation Council, and the AAP. It provides ongoing independent oversight of how the Foundation is operating, and has statutory standing to raise concerns with the Registrar if governance obligations are not being met. The Data Enforcer is appointed by the Foundation Council but must remain independent of it: where Cavendish provides Council services, Data Enforcer appointments are structured accordingly to preserve that independence.
Data Enforcer
Regime Expertise and Knowledge
Cavendish Trust has developed deep working knowledge of the Data Asset Foundation regime from its earliest stages. That knowledge is a core part of what we bring to every engagement, whether as your Foundation Council, Registered Agent, AAP, or Data Enforcer. It means you are not working with a firm that has simply read the legislation: you are working with a team that has followed the framework as it has been built, understands its rationale, and can navigate its nuances.
We work comfortably as your primary service provider or alongside an existing CSP relationship. In either case, the depth of our regime knowledge is available to you as part of the formal engagement. All formal engagements are subject to our standard client onboarding process, including identity verification and our Terms of Business.
Regime Expertise and Knowledge
From first conversation to full registration
Every engagement with Cavendish begins in the same place: understanding your data and your objectives. There is no standard contract and no fixed timeline. Here is what the typical path looks like.
Tell us about your data and your objectives. No preparation required. If you have already run the classification tool, bring your PDF. If not, we can work through it together. There is no obligation at this stage.
We agree the scope of services, confirm the roles Cavendish will hold, and set out the engagement terms. This includes completion of our standard client onboarding requirements. For straightforward projects this can be done quickly. For complex or multi-party structures, we allow time for the scope to develop properly.
We manage the Foundation establishment, registration, and ongoing administration. Our relationship does not end at registration: we provide continuing governance support, accreditation assistance as the framework matures, and regime guidance throughout.
Not sure where you are in this process? That is entirely normal. The DAF regime is new and most enquiries begin with a genuine question rather than a formed view. The classification tool is the easiest way to get oriented before reaching out, but it is not a prerequisite. Reaching out directly is always the right starting point.
Ready to start?
The classification tool takes under ten minutes and gives Rick everything he needs to make your first conversation immediately productive. Or reach out directly if you prefer to start with a conversation.