01
Record retention
Signed AI-check records retained for the monitoring period plus seven years, matching FCRA's adverse-information window under § 1681c. Append-only; records cannot be modified after publication.
Institutions
FCRA exposure and evidence
Institutional counsel carries liability when AI-assisted signals contribute to admit/decline outcomes. The map below ties each applicable FCRA section to the runtime receipt that supports it.
FCRA controls 8 6 verified · 2 partial
Retention 7 yr § 1681c window · append-only
Last verified 02:18 UTC § 1681m(a) chain · today
Verifier offline-capable Ed25519 · no vendor dependency
FCRA control map
Mapping of Fair Credit Reporting Act sections that apply to AI-assisted employment decisions. Residency match is an employment decision under § 1681b(a)(3)(B). 6 of 8 controls verified; 2 partial (runtime ready, per-program ATS/QMS integration is per-tenant rollout).
| Section | Control | Status | Maps to feature | Last verified | |
|---|---|---|---|---|---|
§ 1681m(a) | Adverse-action notification | Verified | Cortex Screening | Tue, 12 May 2026 03:18:42 UTC | |
§ 1681i | Dispute right and reinvestigation | Partial | Cortex Screening | Mon, 11 May 2026 19:44:08 UTC | |
§ 1681e(b) | Reasonable procedures for accuracy | Verified | Career Interest Badge | Tue, 12 May 2026 02:01:11 UTC | |
§ 1681g(a) | Disclosure to consumer on request | Verified | Cortex Screening | Tue, 12 May 2026 00:55:09 UTC | |
§ 1681k | Public-record information for employment purposes | Verified | Grade Normalization | Mon, 11 May 2026 22:19:47 UTC | |
§ 1681s-2 | Furnisher duties (ATS webhook ingest) | Partial | Cortex Screening | Mon, 11 May 2026 16:28:12 UTC | |
§ 1681b(a)(3)(B) | Employment-purpose permissible use | Verified | Cortex Screening | Mon, 11 May 2026 20:41:35 UTC | |
§ 1681q | Obtaining information under false pretenses | Verified | Cortex Screening | Mon, 11 May 2026 15:09:22 UTC |
Representative end-to-end chain showing AI-assisted review documented from AI check through to a § 1681m(a) adverse-action notice. Each step below is a signed record counsel can verify.
- 01
AI checks Three AI features run against the applicant submission
Academic Career Interest Badge, Enhanced Grade Normalization, and Cortex Application Screening each produced a signed record with evidence-span hash and prompt version.
signed r_4f2b9c1e signed r_a83f1c92 signed r_d12e8a07 - 02
Fairness flag Daily test flags name-correlated sensitivity
The daily test set finds the rural-medicine text-analysis prompt sensitive to a name cue. Applicant 2026-04812 eligible for re-analysis.
partial prb-2026-04-30-417 - 03
FCRA § 1681i Applicant opens dispute
Disclosure request and dispute filed. Tracked case
disp-2026-04812-Aopens a reinvestigation receipt chain.signed r_disp_a01e72 - 04
Reinvestigation Reinvestigation resolves; signal unchanged
Re-extraction completes under corrected configuration. Underlying output remains Moderate; disposition published as a signed reinvestigation receipt.
signed r_reinv_b48f12 - 05
Held for review Missing-evidence flag caught before reaching reviewer
On a methodology version bump, the system detected a text analysis citing an evidence span that did not exist in the personal statement. Output held at the system boundary.
quarantined q-2026-04812 - 06
FCRA § 1681m(a) Adverse-action notice (projected pathway)
Should the program decline to interview based in part on AI-assisted signals, the notice links every contributing AI-check record — including the held event — and the dispute pathway. The notice is itself a signed record linkable in court.
02
Evidence-chain integrity
Every per-check record is included in a per-period Merkle tree (RFC 6962). Tree root is signed and published at period close. Counsel can reconstruct any subset and verify inclusion without depending on Thalamus or Glacis.
03
Signed timestamps
Each record carries a wall-time-ns field signed alongside the verification hash. Per-period STH timestamps are independently signed (Ed25519) and verifiable against the embedded public key.