A verification layer, and nothing more than that.
There is a gap between what a vendor publishes and what their customers are told. This exists to close it — not to police anyone, not to score anyone, and not to replace the notice your vendors already owe you.
01 Why this exists
Article 28 gives a controller the right to be told before a processor brings in a sub-processor, and the chance to object. In practice the notice often arrives late, or at an inbox somebody left in 2024, or not at all — and the page quietly changes instead.
Nobody involved is behaving badly. The vendor updated a page and assumed that was the notice; the customer assumed an email would arrive. The gap is procedural, which is why a process closes it.
02 How we work
Machines find candidates. People make decisions. Everything is dated and checkable.
- Detection is arithmetic. Fetch, strip, hash, compare. No model decides whether your list changed, and none can create, alter or suppress a record.
- A named person reviews every discovery and every material change before it reaches you. Their name goes on the record.
- Nothing is published, and no customer of yours is emailed, without your approval. That is not a setting.
- We publish our own gaps — coverage, false-positive rate, and the parts of the problem we cannot reach. A register that only reports its wins is marketing.
03 What we refuse to do
This product could be built as an accusation engine. It is deliberately not.
- We do not say anyone is in breach. A page changed, on a date, with the evidence attached.
- We do not tell you whether you are compliant. That is for you and your advisers.
- We do not write “undisclosed”, infer intent, or rank companies against each other.
- We do not publish a scan of a domain the requester does not control.
- We do not run ads, sell data, or use your contracts to train anything.
04 How we make money
Subscriptions, from businesses whose lists we maintain. That is the whole model.
The register stays free to read, without an account, including the API and the ledger verification endpoint. Charging for the record would make it a worse record, and the argument for trusting it is that anyone can check it.
We do not charge per alert. Metering alarms would give us a reason to raise more of them and you a reason to want fewer, which is the wrong incentive on both sides.
05 Working here
No open roles at the moment — this is a small operation and saying otherwise to collect CVs would be a poor start.
If you are a privacy practitioner who has maintained one of these lists by hand and has strong opinions about why it was miserable, that is the conversation worth having. Reviewer work here is judgement, not data entry, and the people who are good at it have usually been on the other side of it.