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Compliance Boundaries

The contributor portal is built around a conservative Pilot1 operating model. It should help contributors apply, complete documents, and later receive rewards without making PlayRoll look like employment, payroll, a task marketplace, or a required work schedule.

Naming​

Use:

Extrinsic Cognition, Inc. -> legal counterparty, controller, committente, payor
PlayRoll -> recorder and contributor portal product
Contributor -> person participating in voluntary sessions

Avoid:

employee
internship
job
shift
salary
payroll
task marketplace
disciplinary ranking
automatic penalty
mandatory assignment

Contributor Session Constraints​

Contributor-facing and operator-facing docs should preserve these constraints:

  • contributors can accept or refuse each session without penalty
  • no exclusivity
  • no fixed shifts
  • no automatic disciplinary ranking
  • no recorder access before document and tax-status gates are complete
  • no payment before validation, cap, receipt, payout, and approval gates pass
  • downstream customers, labs, buyers, or partners are not named in contributor-facing docs

Data Minimization​

Before recorder access, do not collect:

codice fiscale
full residential address
date of birth
identity document
IBAN
payout method

The onboarding workspace requires an explicit data-minimization acknowledgement. Its version is:

playroll-data-minimization-ack-v1

If a later verification, tax obligation, competent authority request, or payout operation requires sensitive data, collect that data in a later purpose-specific flow and record why it is needed.

Document Evidence​

The current Pilot1 evidence model is self-hosted and JSON-based. It records document versions and hashes, not immutable signed PDFs.

Evidence package version:

playroll-pre-recorder-v1

Document versions:

playroll-lettera-incarico-v1.1
playroll-privacy-ack-v1
playroll-dichiarazione-fiscale-v1.1
playroll-data-minimization-ack-v1

Each accepted item includes:

accepted
accepted_at
auth_user_id
document_hash_sha256
document_id
document_title
document_version
evidence_type
verified_email

This is sufficient as the current Pilot1 evidence layer for recorder access, but it is not the full signing system.

Future Signing System​

A full signing system still needs:

  • exact rendered document version shown to the signer
  • rendered PDF hash
  • email verification or login event
  • typed legal name
  • explicit acceptance checkbox
  • timestamp
  • IP address
  • user agent
  • immutable server-side signed PDF
  • audit event history
  • contributor download copy

Do not treat the current browser text download as immutable document storage.

ISEE And Fiscal Copy​

The portal asks the contributor to acknowledge that rewards may have fiscal or ISEE relevance. EC is not calculating ISEE in the portal and should not present the acknowledgement as tax advice.

No-P.IVA contributors are operationally capped at:

EUR 4,000 rolling 12 months from Extrinsic Cognition, Inc.
Warning threshold: EUR 3,000
Hard stop: EUR 4,000

The cap includes:

cash
software keys
vouchers
prepaid cards
bonuses
referral rewards
manual adjustments

Receiving-Method Copy​

The rewards page must frame IBAN/manual review as a way for the contributor to receive money or rewards. It must not sound like the contributor is paying EC or paying PlayRoll.

Approved wording pattern:

the contributor receives money
the contributor does not pay anything

Current portal-owned receiving-method capabilities:

  • own-name SEPA IBAN
  • IBAN country/length/format/mod-97 validation
  • email confirmation of IBAN
  • manual review request if IBAN is unavailable
  • confirmed/manual-review status for downstream payout code

Not portal-owned:

  • provider recipient verification
  • payout request creation
  • operator approval queue
  • payment execution
  • receipt or value-sheet generation
  • failed payment handling