Phinamek Data LTD — Sovereignty Verification

Supervisory Evidence Pack

Verification ag_09db379bb0c9 · 2026-11-08

Verdict

NO GO

Ruleset:

Inputs hash: (the declaration itself is not retained - only its hash)

Certified by: Director of Digital Services — Permanent Secretary (certified inputs true and complete, )

Findings (3)

HIGH AGENT-001 AG-1 AGENT-001; NDPA 2023, s 41

Agent inference runs in US while deployed in NG — the model's location is a processing location for all data the agent handles.

Remediation: Declare inference location and document transfer safeguards.

MEDIUM AGENT-002 AG-1 AGENT-002; NDPA 2023, s 41

Tool 'translation_api' hosted in US receives data from a NG-deployed agent.

Remediation: Map tool data flows and document safeguards per transfer.

MEDIUM AGENT-003 AG-1 AGENT-003; CBN circular (audit trails in scope)

Agent logs/memory stored in IE — retained data outside NG.

Remediation: Bring log and vector-store storage into jurisdiction or document safeguards.

Privacy - what was retained for this attestation

Certifier retained on this attestation: Director of Digital Services - Permanent Secretary (business capacity).

Retained for this attestation: organisation name; certifier name and title (business capacity); declaration inputs hash; verdict; rule-pack version; attestation ID, issue/expiry dates - for accountability and re-run/dispute verification only. Not retained: evidence documents, data-subject personal data, annotator/personnel files, private contact details. Phinamek verification service privacy statement v1.0.

How to check this printout

This printed pack is a copy. The signed digital original governs, and it can be checked three ways, by anyone, without an account:

1. Match the identifiers. The Verification ID above and the Attestation ID in the attestation block identify the original record.

2. Validate the signature. The attestation is Ed25519-signed; its signature validates offline against Phinamek Data LTD's public key. A tampered copy fails.

3. Re-run the check. The same declaration inputs (hash above) against the same rule-pack version reproduce the identical verdict and findings.