v22.0 Control C1 Legal Review (Telemetry and Re-Identification Clauses)

Control reference:

1. v22.0 Integration Feasibility Decision Record

Control Objective

Reject any external integration terms that require either:

1. re-identification capability, or
2. prohibited telemetry transfer that violates v22 redlines.

Scope

1. Candidate partner contracts and API terms.
2. Addenda related to analytics, retention, and audit obligations.
3. Any data-processing clauses linked to 211 pathway integration.

Current review mode (2026-03-09):

1. Repo-evidence legal readiness review is complete.
2. Candidate external partner contract artifacts are not yet attached in-repo.
3. C1 cannot be fully closed until candidate terms are reviewed clause-by-clause.
4. A canonical drop location now exists for future evidence submissions in v22.0 Evidence Workspace / C1.

Required Clause Checks

• [x] C1-1: No raw user query text transfer requirement.
• [x] C1-2: No forced user-identifying telemetry transfer requirement.
• [ ] C1-3: No re-identification capability requirement.
• [x] C1-4: No conflict with privacy-first constraints in governance standards.

Evidence Snapshot

1. Governance redline baseline:
2. Governance Protocol: The Kingston 150 Standard
3. Privacy and instrumentation controls:
4. ADR-020: v22 Phase 0 Pilot Instrumentation and Privacy Guardrails
5. v22.0 Integration Feasibility Decision Record
6. Comparative/legal-risk context package:
7. CareConnect vs 211 Objective Evaluation (2026-02-27)
8. Submission workspace:
9. v22.0 Evidence Workspace / C1

Evidence Intake Checklist (For Closure)

All items are required to mark C1 complete:

• [ ] Intake artifact C1-partner-terms-bundle attached (contract/API terms/addenda used for review).
• [ ] Clause-by-clause redline notes recorded for C1-1, C1-2, C1-3, and C1-4.
• [ ] Any conflicting clause is explicitly marked reject with rationale and fallback path.
• [ ] Final legal recommendation recorded as one of: acceptable, acceptable_with_conditions, not_acceptable.
• [ ] Evidence links added to this document and v22.0 Integration Feasibility Decision Record.

Acceptance criteria:

1. No unresolved clause remains for C1-3 (re-identification capability).
2. Evidence table contains dated artifact links, reviewer, and status complete.
3. C1 status is synchronized in the Gate 0 checklist/evidence tracker.

Evidence Table

Decision

• Result: pending
• Blocking findings: Candidate partner terms are not yet attached for clause-level legal review (C1-3 unresolved).
• Escalation needed: Obtain candidate partner legal/API terms and run clause-level redline review by 2026-03-21.

Verification Note

Completion requires updating C1 status in v22.0 Integration Feasibility Decision Record.