{
  "id": "CMP-122",
  "slug": "cmp-122",
  "title": "The opt-in screenshot must show the terms and privacy links",
  "statement": "A screenshot submitted as opt-in evidence must show the Terms and Privacy Policy links as the consumer sees them.",
  "rationale": "The links being present on the page is not the question — the question is whether they were visible at the moment of consent, and only the screenshot answers it. A footer link three screens below the form is on the page and was not part of the decision, which is the distinction reviewers are looking for when they ask for this framing.",
  "layer": "CAMPAIGN",
  "layerSlug": "campaign",
  "object": "opt-in screenshot",
  "severity": "HIGH",
  "detectability": [
    "VISION"
  ],
  "failureClass": "TERMINAL_EVIDENCE",
  "authorities": [
    "LeadConnector",
    "Twilio"
  ],
  "codes": [
    {
      "provider": "Twilio",
      "code": "30909",
      "remediable": true
    }
  ],
  "applicability": {
    "consentMethods": [
      "web_form",
      "checkout"
    ]
  },
  "applicabilityText": "Applies when consent was collected by web form and checkout.",
  "universal": false,
  "remediation": "Re-frame the screenshot to include the consent control and the terms and privacy links in one image. If they do not fit in one frame, move the links up beside the control rather than stitching two screenshots together.",
  "pitfalls": [
    "Stitching a crop of the form to a crop of the footer proves the opposite of what it is meant to: it shows the two were not visible together."
  ],
  "catalogIds": [
    "POL-036"
  ],
  "phase": "approval",
  "automated": true,
  "url": "https://ekas.io/rules/10dlc/campaign/cmp-122/",
  "markdown": "https://ekas.io/rules/10dlc/campaign/cmp-122.md",
  "registry": "https://ekas.io/rules/10dlc/",
  "updated": "2026-07-25",
  "licence": "CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/"
}