Compliance Justification Document (Spokeo, Inc. v. Robins)

Map controls to FCRA accuracy obligations.

---

Purpose

This mapping document shows how implemented controls satisfy obligations and expectations implicated by Spokeo, Inc. v. Robins. It is structured for audit and legal review, so each requirement is tied to implementation rationale, ownership, and verifiable artifacts rather than policy statements alone.

Control mapping (summary)

Obligation theme	Control / evidence	Notes
Source integrity	Source catalog; ingestion contracts; deprecation process	Reduce unreliable feeds
QA and monitoring	Sampling reports; defect tracking; model change control	Demonstrate ongoing reasonableness
Human review	Review queue logs; reviewer training records	High-risk attributes
Disputes	Ticket system; investigation SOPs; consumer communications	Concrete harm reduction
Access security	IAM, logging for internal tools	Prevents malicious alteration

Document-type guide: Compliance Justification Document

Writing tips: Writing best practices — Compliance Justification Document