Phase 11 Wave 0 Owner Action Packet¶
Current decision: ENTRY_BLOCKED_EXTERNAL
Repository state: technical preparation in progress; participant entry disabled
Governing issue: #112
Purpose¶
This packet contains only the serious actions that require the owner, a regulator, qualified Zambia counsel or protected provider consoles. Routine repository implementation and verification remain agent-owned.
1. Zambia DPC controller/processor registration¶
Submit the actual DIREKT entity/application through the DPC process and preserve:
- applicant/entity legal name and registration number;
- controller, processor or combined classification requested;
- DPC application/reference identifier;
- submitted data-flow/topology version;
- official invoice and proof of payment where applicable;
- official certificate, rejection, clarification request or other outcome;
- validity/renewal date and conditions.
Official starting points:
- https://www.dataprotection.gov.zm/registration/
- https://registration.dataprotection.gov.zm/
Closes: P11-G01 only after the actual official outcome is supplied and reviewed.
2. Overseas storage and transfer authorization¶
The DPC portal states that separate authorization is required when personal data is transferred or stored outside Zambia. Submit the exact approved topology, including:
- Supabase project and hosting region;
- Google Cloud services and regions;
- Firebase Authentication and related data flows;
- subprocessors and contractual roles;
- categories of data and data subjects;
- retention, deletion, encryption and access controls;
- data-flow diagram/version.
Preserve the official application/reference, determination, authorization, conditions and expiry.
Closes: P11-G02 only after entity/topology-specific evidence is supplied.
3. Qualified Zambia legal review¶
Give qualified Zambia counsel the exact repository packet and request a signed, scoped review covering:
- controller/processor and joint-controller roles;
- lawful bases and consent design;
- sensitive data and evidence handling;
- cross-border storage/transfer requirements;
- participant rights, access, correction, withdrawal and deletion;
- retention schedule and legal holds;
- provider/customer terms;
- verification and trust-claim limitations;
- complaints, moderation, redress and consumer-protection obligations;
- field activity and safety only if later enabled;
- whether the initial no-payment, no-external-communications, no-Maps, no-participant-telemetry design is acceptable.
The review must identify the exact document versions reviewed, unresolved questions and conditions.
Closes: P11-G03 and P11-G04 only after the signed review is supplied.
4. Approve the final participation notice and lifecycle schedule¶
After counsel review, approve an immutable pilot_participation_notice version with:
- effective date;
- controller identity and contacts;
- purposes, data categories and recipients;
- overseas storage/transfer disclosure;
- retention and deletion rules;
- withdrawal and complaint process;
- verification/trust limitations;
- communication, telemetry, Maps, AI and payment exclusions;
- version checksum.
Also approve the linked consent, retention, deletion and withdrawal operating schedule.
Closes: P11-G05 and P11-G06 after the exact approved artifacts are supplied and registered through the protected pilot process.
5. Sign the Wave 1 authorization¶
Record the exact operating decision:
- wave ID and dates;
- maximum and actual provider/customer counts, never above 8 and 20;
- Lusaka geography and exact neighbourhood boundary;
- allowed service categories;
- provider pathway allocation;
- recruitment method and invitation expiry;
- named pilot, privacy/security, support, incident and verification owners;
- support hours, escalation path and daily review time;
- numeric pause thresholds;
- confirmation that field claims, Maps, participant telemetry, external messaging, AI, payments and automated registry access remain disabled unless separately approved.
Closes: P11-G07 and supports P11-G13.
6. Configure Firebase Zambia phone authentication¶
In the protected Firebase console for the approved Android app:
- confirm project/app/package identifiers;
- register the exact approved SHA-256 and SHA-1 fingerprints;
- enable Phone Authentication only for the approved pilot project;
- allow Zambia in the SMS region policy and keep other regions denied unless justified;
- configure quotas, abuse monitoring and billing controls;
- confirm Play Integrity behavior;
- confirm reCAPTCHA fallback behavior for non-Play-distributed or unsupported devices;
- verify approved phone-number disclosure/notice language;
- preserve sanitized screenshots/exported settings and accountable-owner attestation.
Do not use real participant numbers for the first configuration proof.
Closes: P11-G08 after configuration evidence is supplied. P11-G09 still requires the separately authorized managed real-environment canary.
7. Supply protected environment and operations evidence¶
After P11-G01 through P11-G08 are closed, authorize a managed pre-participant canary lane for:
- invitation/auth/consent;
- private upload/read/revoke/delete;
- withdrawal/re-entry block/deletion/retention/audit;
- exact deployment revision, image digest, configuration receipt and migration checksums;
- support and incident rehearsal.
No real participant recruitment begins merely because these canaries pass.
Closes: P11-G09 through P11-G13 only through the later managed evidence lane.
Evidence submission format¶
For each gate, provide:
Gate ID:
Decision: CLOSED / NOT APPLICABLE / REMAINS OPEN
Evidence authority:
Evidence reference:
Evidence file SHA-256:
Exact scope/topology/document version:
Decision owner:
Decision date/time with timezone:
Conditions and expiry:
Independent reviewer where required:
Do not send regulator certificates, legal opinions, IDs, phone numbers, credentials or private participant material in public GitHub comments. Use the approved private evidence channel and record only sanitized references/hashes in the repository.
Current stopping point¶
Until the required evidence above exists, the only truthful terminal decision is:
ENTRY_BLOCKED_EXTERNAL
PILOT_ENTRY_APPROVED stays false, PRIMARY-PILOT evidence stays empty and Phase 12 stays unauthorized.