Touli Compliance-by-Design Controls

Purpose

Map legal and privacy requirements into concrete architecture controls and operational checkpoints for AI verification, points, and blockchain modules.

Control Framework

Each control includes:

• Requirement source
• Architectural control
• Enforcement point
• Evidence artifact

Core Controls

1) Data Residency and Transfer Control

Requirement:

• EU data in EU region, cross-border safeguards; KSA and PH constraints by market.

Architecture control:

• Market-aware routing policy at ingest.
• Region-scoped data-plane configuration and processor boundary.

Enforcement point:

• API ingress policy engine + environment segregation.

Evidence:

• routing decision logs, region config snapshots, transfer agreement registry links.

2) Age Gate and Parental Consent

Requirement:

• Jurisdiction-aware digital consent age; PH under-18 parental consent requirement.

Architecture control:

• Country-aware registration policy service.
• Immutable consent audit records.

Enforcement point:

• Account creation and auth workflows.

Evidence:

• consent_audit entries with timestamp, consent version, ip hash.

3) Minor Safety Restrictions

Requirement:

• Disable random gifting and unsafe adult interactions for minors.

Architecture control:

• Eligibility policy checks before matching and gifting.
• Feature-flag restrictions by account age class.

Enforcement point:

• Matchmaking hard filter and messaging policy service.

Evidence:

• policy decision logs, denied action reason codes.

4) Sensitive Inference Consent Gate

Requirement:

• Explicit consent before sensitive cultural/religious inference contexts in applicable markets.

Architecture control:

• Scoped consent token required before enabling relevant preference inference features.

Enforcement point:

• Profile enrichment pipeline and matching context filter.

Evidence:

• consent scope records + feature-use audit logs.

5) AI Decision Contestability

Requirement:

• Human intervention path for materially significant automated outcomes.

Architecture control:

• Manual review queue and appeal pathway.
• Decision provenance with reason codes.

Enforcement point:

• Verification outcome API + review service.

Evidence:

• review tickets, adjudication timestamps, outcome deltas.

6) Retention and Deletion Control

Requirement:

• Precise GPS and verification images deleted within policy windows.

Architecture control:

• Scheduled retention worker and immutable deletion logs.

Enforcement point:

• Data lifecycle jobs over evidence store and coordinates fields.

Evidence:

• retention_action_log with policy version and execution result.

7) Data Minimization and Purpose Limitation

Requirement:

• Collect only required data and avoid prohibited categories.

Architecture control:

• strict input schema allowlists by endpoint
• prohibited-category classifier and rejection guardrails.

Enforcement point:

• submission service validators + moderation controls.

Evidence:

• schema validation logs and blocked payload reason codes.

8) Blockchain Privacy Control

Requirement:

• No identifiable personal data on-chain; preserve deletion rights.

Architecture control:

• pseudonymous rotating subject identifiers
• off-chain mapping destruction on erasure requests.

Enforcement point:

• anchor leaf generation + erasure workflow.

Evidence:

• erasure completion logs + anchor mapping tombstone records.

9) Processor Governance Control

Requirement:

• Written processor agreements and restricted processing purpose.

Architecture control:

• processor registry integrated into deployment readiness gates.

Enforcement point:

• release checklist and environment admission policy.

Evidence:

• signed DPA registry entries and compliance gate status.

Operational Checkpoints

Pre-implementation checkpoint

• Confirm market launch sequence and age/consent matrices.
• Confirm residency routing and processor scope per market.

Pre-integration checkpoint

• Verify consent scope instrumentation is in contract docs.
• Verify manual review and appeal contracts are finalized.

Pre-go-live checkpoint

• Run retention/deletion dry-run and evidence sampling.
• Run decision reproducibility drill (submission -> decision trace).
• Run anchor unlinkability and erasure simulation.

Post-go-live checkpoint

• Weekly compliance metrics review.
• Incident simulation for AI outage and delayed deletion.
• Quarterly policy-to-architecture drift review.

Control-to-Metric Mapping

Control	Metric
Age/consent	invalid_age_registration_block_rate
Minor restrictions	blocked_minor_random_gift_count
Human review rights	appeal_turnaround_sla
Retention deletion	deletion_sla_compliance_rate
Residency routing	cross_region_write_violation_count
Chain privacy	onchain_pii_violation_count

RACI (Architecture Stage)

• Legal/Compliance: policy interpretation and sign-off.
• Architecture owner: control design and traceability.
• Backend owner: enforcement point implementation plan.
• Data owner: retention and residency mechanics.
• QA/SRE: control verification and observability.