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Compare: certified consent today

The incumbent model for lead-flow consent certification — TrustedForm (which now also owns Jornaya) — records a session replay and a certificate URL, held in the vendor’s custody. It answers “did they consent?” with “we saw it, trust us.” That model has real value, but it has a structural ceiling: the evidence is only as good as the custodian’s word and continued existence.

Question an auditor asks Custody model SP/1
Could the vendor alter a record after the fact? Unfalsifiable — you have their word Detectable: fingerprint + hash chain + external anchors break
Can I verify without the vendor’s cooperation? No — certificate lookup requires the vendor Yes — recompute hashes from the spec; verify Merkle proofs against a pinned key
What exactly was disclosed, verbatim? Session replay (pixels; requires playback trust) Disclosure text + SHA-256, committed into the fingerprint
Were the named recipients bound in? (one-to-one) Depends on what the page showed; not a commitment entities list is sorted and hashed into the fingerprint
Which terms were in force at opt-in? Not captured Policy snapshots, content-hash-deduplicated
What happened after consent — revocation, cease? Out of scope First-class lifecycle with obligation clocks; silence is evidence
Can the consumer see and control their record? No The subject holds, monitors, revokes — it’s their grant
If the vendor disappears, does the evidence survive? Effectively no Anchored commitments survive in an independent ledger; verifiers need only the spec

SP/1 is not a claim that custody models are useless — replay artifacts are persuasive and familiar. The claim is narrower and stronger: evidence whose integrity depends on trusting one company is weaker than evidence anyone can recompute. A market with a single certification vendor is exactly the market that should demand operator-independent verification.

CMS one-to-one consent requires that the consumer agreed to sharing with the specific named entities. In SP/1 the entity list is not a screenshot detail — it is a sorted, hashed component of the certificate fingerprint. Adding an entity after the fact is not “hard to notice”; it is a different hash.

Try it live: the demo issues real certificates with public verification pages.