{
  "id": "OPS-232",
  "slug": "ops-232",
  "title": "A spoken opt-in needs a per-consumer artifact, not just a script",
  "statement": "Verbal consent must be evidenced per consumer by a recording, a transcript, or documented contemporaneous notes — never by the script alone.",
  "rationale": "The script proves what the programme intends to say. It is silent about any particular call, so a brand holding only a script has one document and no evidence, and finds that out when a single complaint asks about a single consumer. The transcript or the note is the substitute a reviewer accepts when a recording does not exist, which is why the rule names three acceptable forms rather than demanding audio.",
  "layer": "OPERATIONAL",
  "layerSlug": "operational",
  "object": "campaign.message_flow",
  "severity": "HIGH",
  "detectability": [
    "AI_FORM"
  ],
  "failureClass": "RETRY_FIELD",
  "authorities": [
    "FTC",
    "practice"
  ],
  "applicability": {
    "consentMethods": [
      "verbal_live",
      "verbal_ivr"
    ]
  },
  "applicabilityText": "Applies when consent was collected by live verbal and IVR.",
  "universal": false,
  "remediation": "Name in the message flow which artifact is kept per consumer — recording, transcript, or a contemporaneous CRM note carrying the verbatim assent — and keep it against the number. Done when the flow says what exists for one named consumer, not what the agents are told to say.",
  "example": "Each phone opt-in retains the call recording; where the consumer declines recording, the agent stores the verbatim assent and the script version in the CRM against the number.",
  "notes": "Absorbs OPS-234, which states the transcript fallback inside the same record requirement. Whether a recording can stand as WRITTEN consent for a marketing programme is a different question and is judged by CON-156; this rule asks only whether any per-consumer artifact exists.",
  "catalogIds": [
    "OPS-234"
  ],
  "phase": "approval",
  "automated": true,
  "url": "https://ekas.io/rules/10dlc/operational/ops-232/",
  "markdown": "https://ekas.io/rules/10dlc/operational/ops-232.md",
  "registry": "https://ekas.io/rules/10dlc/",
  "updated": "2026-07-25",
  "licence": "CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/"
}