The catalog
The catalog is the company's declaration of what it collects and the purposes it
collects it for. It is a set of cells, each a (category, purpose) pair: a
category of personal information (the what) crossed with a purpose (the why).
Phone number x Billing is a distinct cell from Phone number x Marketing.
Everything else rests on it: a consent document groups catalog cells, and a
consent request targets catalog cells.
The catalog is bilingual, and that is the law
Each cell carries a category and a purpose label in French, which are the
primary columns. English is provided as optional sibling columns, category_en
and purpose_en, shown to a person who is reviewing in English, with a fallback
to French when a translation is missing. The cell's description is
French-only; it is an internal note for the organization and is not shown as-is
to the person concerned.
Bilingualism is not a convenience: it serves the validity of the consent.
A consent the person cannot understand is without effect
Article 8 para. 4 of Law 25 requires the consent request to be presented "in clear and simple language", and article 14 requires consent to be "informed". A person must be able to understand what they are consenting to in their own language. If the disclosure shown to an English-speaking citizen exists only in French (or the reverse), the consent collected may be treated as without effect. Filling in the English columns is therefore not optional once an offer can reach an English-speaking person.
Normalized keys and deduplication
Alongside its display labels, each cell carries a normalized category key
(category_key) and purpose key (purpose_key), derived from the French
label. The key is the label trimmed, with internal whitespace collapsed, and
lowercased. These keys do two things: they deduplicate the catalog (two cells
cannot declare the same pair twice) and they are the stable hinge on which
approval and verification index.
Because the key derives from the French, the join never re-keys: translating or tweaking the English label does not move the cell, and a consent granted under it stays attached to the same cell.
Locking: a rename can never orphan a consent
As soon as a cell is referenced by a consent, it is locked against renaming. The logic is simple and protects the person concerned: if a cell under which an active consent exists could be renamed, that consent would suddenly point at something other than what the person accepted. The lock prevents it. As long as no consent attaches to it, the label stays editable.
Archiving and restoring
A cell can be archived and then restored. Archiving is catalog hygiene: it removes a cell from active views without destroying it, for example when a purpose is no longer pursued.
Archiving is not withdrawing consent
Archiving a cell touches no consent decision. A consent granted under an archived cell remains exactly what it was; withdrawal of consent stays per cell, at the initiative of the person concerned or the company. Archiving tidies the catalog; it revokes nothing.
The cell detail page
Each cell has a detail page that gathers what depends on it:
- The consent documents that attach it: the versioned disclosures that group this cell among their items.
- Your own customers who accepted or declined it: the count is company-scoped, indexed on the organization's customer id. The page never shows a citizen's decentralized identifier; the company sees its customers, not the person's protocol identity.
- The lock state: the page shows whether the cell is locked because a consent references it.
Automated decision (article 12.1)
A cell can be flagged as feeding a decision based exclusively on the automated processing of personal information. This flag serves the transparency article 12.1 of Law 25 requires: it lets the company know which cells feed an automated decision and account for it when drafting the disclosure, which must then signal it to the person concerned. The flag on the cell is a governance signal; the text shown to the person lives in the consent document.
Next
- Consent documents: how catalog cells are grouped into an article 8 disclosure.
- Consent requests: issuing an offer over catalog cells.
- Core concepts: the
(category, purpose)grid and the normalized key, protocol-side.