# Eight-Pass Review Log

Review date: 2026-07-09  
Method: simulated professional legal, judicial, client, privacy, security, product, healthcare, and integration review. This is not a legal opinion.

## Pass 1 — Source authenticity and freshness
Reviewed sources for official origin and recency. Preferenced FTC, HHS, FDA, NIST, California DOJ/CPPA, European Commission, ICO, Apple, Google, ADA.gov, and W3C. Added a source map and marked IAPP as a non-government tracker requiring statutory verification.

## Pass 2 — U.S. privacy baseline
Checked for FTC deception/unfairness risks, clear privacy promises, data minimization, data-security language, state privacy rights, CCPA notice-at-collection, opt-out, sensitive data, request verification, appeals, and non-discrimination. Added Do Not Sell/Share notice, state addendum, DSAR policy, and GPC handling.

## Pass 3 — Marketing and analytics review
Reviewed email, SMS/push, pixels, SDKs, ad audiences, testimonials, and suppression list handling. Added CAN-SPAM-oriented requirements, advertising opt-out controls, health/children/sensitive-data prohibitions, and campaign-review triggers.

## Pass 4 — Healthcare, healthtech, and hospital review
Reviewed HIPAA role separation, BAA dependency, PHI handling, Health Breach Notification Rule, hospital patient-rights routing, tracking on patient pages, FDA device software classification, clinical AI, and information-blocking risk. Added separate Healthcare, HealthTech, Hospital, Telehealth, BAA, and NPP checklist files.

## Pass 5 — AI policy review
Reviewed AI transparency, training restrictions, high-risk use cases, human oversight, bias, testing, vendor review, healthcare AI, and recordkeeping. Added AI risk tiers, model-provider review, AI system register, and warnings against sole automated significant decisions without review.

## Pass 6 — Quantum and security review
Reviewed cryptographic agility, post-quantum readiness, long-lived confidentiality, vendor crypto roadmap, and unsupported claims. Added NIST-aligned PQC inventory, migration priorities, and a prohibition on unsupported “quantum-impervious” claims.

## Pass 7 — Judge/adversarial review
Looked for overbroad promises, contradictions, missing definitions, ambiguous roles, unenforceable absolutes, and risky compliance claims. Replaced absolute claims with reasonableness, evidence, and counsel-review language. Added role distinctions for controller/processor/service provider/business associate.

## Pass 8 — Client and implementation review
Checked whether a client can publish, wire, maintain, and prove compliance. Added implementation guide, footer snippets, cookie banner, privacy request forms, compliance CSVs, placeholder config, and publication warnings. Verified JSON syntax, internal links, HTML parseability, and zip creation.

## Residual risks requiring counsel
- State privacy-law coverage and exemptions.
- Sector-specific laws: HIPAA, GLBA, FERPA, COPPA, biometrics, state health privacy, employment, insurance, payments, telecom, international laws.
- Arbitration/class-waiver/enforceability and consumer terms.
- Medical device, FDA, clinical safety, and AI claims.
- Cross-border transfer strategy.
- Product-specific data flows and vendor contracts.