Designation Record

Interim Founder-DPO under UK GDPR Art. 37(2)

This page is the public, citable record that closes Graduation Gate 1 in its interim form. The closure is honest, narrow, and automatically reverses the moment the conditions in §6 below are met.

§1 Legal basis

TLTE C.I.C. is a UK micro-organisation. Under UK GDPR Article 37(1) it is not strictly required to designate a DPO at this scale of processing. Article 37(2) permits — and we exercise — a voluntary designation in order to publish a single accountable point of contact for data-protection enquiries and to evidence good-faith intent ahead of any future intake design. This designation is voluntary, public, and revocable only via the Continuity Changelog under the two-Witness rule.

§2 Designated person

Role: Interim Data Protection Officer (founder-DPO)
Identifier: Witness A — Founder of TLTE C.I.C.
Independence note: Voluntary designation under Art. 37(2). The independence standards of Art. 38(3) are aspired to but cannot be fully evidenced while the role is held by the founder. This is disclosed openly rather than concealed.
Era: Aarambam · founding

§3 Public contact channel

Data-protection enquiries (subject access requests, rectification, erasure, objection, DPIA questions) should be sent to:

dpo@tlte.cloud

Acknowledgement target: within 5 working days. Substantive response target: within UK GDPR statutory deadlines (Art. 12(3) — one month, extensible by two further months for complex requests). Where TLTE is not the appropriate body (e.g. survivor testimony, criminal complaints), the response routes the enquirer to PEARL · ITJP · OMP · OHCHR · UK 999 / Refuge — see §5.

§4 Scope of this designation

The interim founder-DPO is the single accountable point of contact for:

· public-site data processing (authentication, session cookies, analytics);
· the citations registry and docs corpus;
· any data held in support of the Continuity Protocol and Stewardship Register;
· any data held in support of the Reception Ledger;
· Velicham AI request / response logging.

§5 Out of scope · hard limits

This designation does not authorise:

· any survivor, witness, family-of-the-disappeared, or CRSV intake;
· any tip-line, DM channel, "secure form", or GlobaLeaks deployment;
· any naming of perpetrators, survivors, or families;
· any aggregation of disappearance, CRSV, or fisher-incident counts;
· any processing that would require a published DPIA under Art. 35.

Enquiries that fall into these categories are routed to the appropriate accredited body.

§6 Automatic reopen trigger

Gate 1 returns to open the moment any one of the following is contemplated, regardless of whether code has shipped:

(a) any intake channel touching first-person testimony;
(b) any matching of records that could identify a survivor / family / witness;
(c) any large-scale or systematic monitoring described in Art. 37(1)(b);
(d) any processing of special-category data under Art. 9 at scale;
(e) growth of TLTE beyond micro-organisation thresholds.

Reopen requires a UK-qualified, independent DPO — not a founder-DPO. This is binding on future versions of TLTE.

§7 Supervisory authority

The UK supervisory authority for data protection is the Information Commissioner's Office (ICO). Any person who believes their data-protection rights have been infringed by TLTE may complain to the ICO without going through TLTE first.

ico.org.uk · make a complaint

§8 Witness rule

This record is co-witnessed under the Continuity Protocol from Entry 4 onward:
· Witness A — Founder of TLTE C.I.C.
· Witness B — Continuity Witness · sealed identifier cw-02-aarambam
Revocation or substantive amendment of this designation requires a new Continuity Changelog entry co-witnessed by both Witnesses.

All gates Continuity Changelog Stewardship Register

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