The legal custodian of a public records database may differ from the custodian of the original underlying records, complicating accountability for data access and privacy.

Court rulings in North Carolina have established that databases aggregating multiple record sources become new records with distinct custodians. This means that the entity managing the database, not the original record holder, is responsible for providing access under public records laws, which complicates governance and introduces ambiguity around data stewardship and privacy protections.