# Phase 11 Secondary-Evidence Substitution Matrix

**Purpose:** Define exactly where current official/credible online evidence may close an entry assumption and where only primary pilot or external approval evidence is valid.

## Evidence classes

- **SECONDARY-OFFICIAL** — current regulator, government, statistics, local-authority or official provider documentation.
- **SECONDARY-CREDIBLE** — credible institutional research used only when official data is incomplete.
- **OWNER-DECISION** — bounded product/operations decision made by the accountable owner from available evidence.
- **EXTERNAL-APPROVAL** — certificate, authorization, signed/provider/legal approval that must actually exist.
- **PRIMARY-PILOT** — consented real participant/field/operational evidence.
- **SYSTEM-METRIC** — measurement from the approved real pilot runtime.

## What secondary evidence may legitimately close

| Decision/gate | Acceptable evidence | Phase 11A status |
|---|---|---|
| Zambia law/regulator applicability questions | current DPC/BoZ/CCPC/other official sources + conservative interpretation | Research complete; final qualified legal sign-off remains external |
| Controller filing direction | DPC categories + known operating structure + owner decision | Individual-controller filing path selected |
| Need for overseas storage/transfer authorization | DPC official registration/FAQ materials | Determined applicable to current overseas topology; authorization itself pending |
| Pilot geography | census/local-government/electoral/operational sources + owner decision | Kabwata + Chilenje approved for entry |
| Comparison geography | official local-government/constituency evidence | Matero evaluated as later stress/expansion candidate |
| Limited categories | official training/registry/licensing sources + implemented evidence architecture | Four categories approved for entry |
| Cohort cap/wave design | risk, support, verification and architecture capacity assumptions + owner decision | 24 providers/60 customers in 3 waves |
| Provider pathway mix | existing domain model + inclusion objective | target 2/2/2 per category |
| Support hours/escalation | operating capacity decision | Approved |
| Numeric pause/stop thresholds | conservative risk-based owner decision | Approved as pilot control limits |
| Device/network test matrix | Android support range + Zambia ICT heterogeneity evidence | Approved |
| Initial provider minimization | architecture/fallback capability + privacy/risk evidence | Maps/Sentry/payments/production comms disabled Wave 1 |
| Authentication provider direction | official Firebase support/privacy/security/region docs + existing GCP/Firebase boundary | Firebase phone OTP selected direction; activation pending |
| Consent/retention baseline | DPC principles + data-minimization architecture + owner decision | Product-approved baseline; legal/DPC review pending |

## What secondary evidence can never substitute for

| Required evidence | Why it cannot be desk-researched into existence | Current status |
|---|---|---|
| DPC controller registration certificate/reference | regulator-issued evidence | Pending |
| DPC overseas transfer/storage authorization | regulator-issued authorization | Pending |
| Qualified Zambia legal sign-off | professional review of exact product/data/terms | Pending |
| Final processor contract/DPA approval | must bind the actual provider/account/topology | Pending for real pilot providers |
| Participant informed consent | individual act tied to exact notice/version | Not started |
| Provider onboarding completion/abandonment | real user behavior | Not started |
| Evidence rejection/resubmission rates | real evidence workflow | Not started |
| Trust-language comprehension | participant understanding cannot be inferred from copy alone | Not started |
| Search/no-result behavior | real cohort/system behavior | Not started |
| Enquiry response/unanswered rate | real provider/customer interaction | Not started |
| Contact-consent comprehension/revocation | real interaction behavior | Not started |
| Field verification time/cost/safety | real Zambia field operations | Not started; field claims disabled |
| Real device/network crash/upload/recovery rates | requires real hardware/network conditions | Not started |
| Support/moderation workload | requires real cases | Not started |
| Willingness to pay/price preference | requires participant evidence; desk pricing is not demand validation | Not started |
| Unit economics | requires measured pilot cost/time plus demand evidence | Not started |
| STOP/REPEAT/NARROW/PROCEED exit decision | must synthesize actual Phase 11 evidence | Pending |

## Rules for progression

1. Official online evidence may **close an assumption or support an owner decision** when the question is factual, regulatory, infrastructural or scope-setting.
2. It may not be relabelled `PRIMARY-PILOT` merely because no participants are yet available.
3. Where official sources establish that an authorization is required, the gate becomes clearer but remains closed until the authorization is actually evidenced.
4. A product decision may proceed conservatively by disabling an optional provider/feature; this can remove that provider from the entry critical path.
5. The absence of Maps, Sentry, payments or production communications does not block Wave 1 because DIREKT has manual/fallback paths and those providers are explicitly disabled.
6. Real participant processing cannot start until the remaining external-approval gate is satisfied.
7. Phase 11 cannot close until required primary/system evidence is produced or the exit decision is `STOP` because the pilot cannot lawfully/safely proceed.

## Result

Online and prior research can materially advance Phase 11A by converting vague unknowns into explicit decisions and a very small set of external blockers.

It cannot truthfully make 11C–11H “complete” before a real pilot exists. Those stages remain evidence-producing stages rather than documentation exercises.
