{
  "id": "OPS-109",
  "slug": "ops-109",
  "title": "The scrub process needs writing down, version dates included",
  "statement": "The registry access and scrub process must be documented, including the registry version date used for each scrub.",
  "rationale": "The defence to a registry claim is the scrub, and a scrub with no record of which registry version it used cannot answer the only question that matters — whether the number was on the list at the time. Documenting the process is also what makes the freshness requirement auditable rather than aspirational.",
  "layer": "OPERATIONAL",
  "layerSlug": "operational",
  "object": "scrub process documentation",
  "severity": "HIGH",
  "detectability": [
    "HUMAN"
  ],
  "failureClass": "TERMINAL_EVIDENCE",
  "authorities": [
    "FCC"
  ],
  "applicabilityText": "Applies to every 10DLC registration.",
  "universal": true,
  "remediation": "Write down who holds the registry subscription, how often it is refreshed, where the scrub runs in the send pipeline, and store the version date with every scrub result. Done when any past send can be tied to the registry version that cleared it.",
  "example": "Scrub log: send acme-2026-03-04, registry_version 2026-03-01, 40,000 in, 312 removed.",
  "notes": "Documentation and logs inside the brand. What the user has to do is keep the version date specifically — most scrub tooling logs a result and a count and drops the version, which leaves the record unable to answer the question it exists for.",
  "phase": "post",
  "automated": false,
  "attestation": {
    "question": "Can any past send be tied to the registry version that cleared it?",
    "howToCheck": [
      "Write down who holds the registry subscription, how often it is refreshed, and where the scrub runs in the send pipeline.",
      "Store the version date with every scrub result — most scrub tooling logs a result and a count and drops the version."
    ],
    "failureLooksLike": "A scrub with no record of which registry version it used cannot answer the only question that matters: whether the number was on the list at the time."
  },
  "url": "https://ekas.io/rules/10dlc/operational/ops-109/",
  "markdown": "https://ekas.io/rules/10dlc/operational/ops-109.md",
  "registry": "https://ekas.io/rules/10dlc/",
  "updated": "2026-07-25",
  "licence": "CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/"
}