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Legal basis register and receipts

Some Noxtica features stay off until your organisation records the legal basis it relies on. Backoffice keeps those records as receipts. A tenant administrator records, changes or withdraws a receipt. This page explains the register, the Replay legal basis, the per-domain consent decision and the errors you see when a receipt is missing.

A receipt is your organisation’s statement as controller. It is not a record that any visitor consented, and it never replaces visitor consent. Noxtica does not tell you which basis to choose. Ask your counsel.

What it is

Availability: depends on your plan, role and the modules enabled for your organisation.

The Legal Basis Register (Backoffice → Privacy & Legal → Legal Basis Register) lists each gated feature, called a gate. For each gate you see whether a basis is recorded (“Asserted” or “Not asserted”), the Article 6(1) basis, the Article 9(2) condition where one applies, the disclosure text you accepted, the receipt version and who recorded it.

Records are immutable and versioned:

  • Change basis records a new version and keeps the previous one. A reason is required.
  • Withdraw keeps the record with status “Withdrawn”. A reason is required. Processing that relies on the basis stops.
  • Nothing is deleted. Every action is logged with who did it, their role, the workspace and the time.

A Noxtica platform administrator can also record a basis for your workspace where that capability is enabled. The receipt then carries the actor role “superadmin”, and your administrators can see it. It never substitutes for visitor consent.

Each receipt pins the exact disclosure text you read, by version, language and a digest. The register shows that text unchanged. If no disclosure is published in your current language, the register refuses to record a basis and does not fall back to another language.

Gates in the register

Register entries use these labels. “Required” means Backoffice asks for an Article 9(2) condition. “Optional” means the dialog offers a condition for use when special-category data is in scope. Whenever you assert a condition you also type the gate key to confirm it.

Register entryArticle 9(2) conditionNote
Investigations moduleOptionalAlso covers Related Devices.
Assistant write actionsOptionalThe sub-processor acceptance for the AI assistant.
Granular sub-fingerprint axesNot acceptedArticle 6(1) is limited to legitimate interests.
Behavioral tracks (pointer/touch)Required
JA4H HTTP fingerprintingRequired
Behavioral baselineRequired
Fingerprinting: CSS system colours & fontsRequiredFixed 365-day term.
Fingerprinting: font enumerationOptionalFixed 365-day term.
Fingerprinting: window-key litterOptionalFixed 365-day term.
Fingerprinting: emoji geometryOptionalFixed 365-day term.
APM and host telemetry ingestOptionalAPM is In development. New Ingestion API keys are bound to the receipt.
KYC raw evidence storageOptionalIdentity verification.
KYC behavioral captureOptionalIdentity verification.
KYC delegationOptionalIdentity verification.
KYC voice profilingRequiredIdentity verification. Takes effect when the platform switch is also on.
KYC age and gender estimationRequiredIdentity verification. Takes effect when the platform switch is also on.

The register shows the expiry date of a receipt that has a fixed 365-day term. Which entries appear depends on what is enabled for your organisation.

Features that refuse to start without a receipt

FeatureWhat you see without a receipt
Session replay on a domainEnabling replay is refused with replay_receipt_required.
Looser replay masking on a domainThe change is refused with the same error, even on a disabled policy.
Hosted identity verificationMinting or submitting a hosted session is refused with kyc_legal_basis_receipt_required (HTTP 403).
Investigations and Related DevicesThe module reads as off and the Related Devices page says it needs a recorded lawful basis.
Granular sub-fingerprint axesThe values are not persisted until an active legitimate-interests receipt exists.
APM ingestion keys (In development)Creating a key is refused with apm_legal_basis_required until a receipt exists.
Console-log and error-detail captureCapture stays off until the domain records a legal basis or requires visitor consent.

Other register entries record your basis. This page does not claim that every entry blocks a feature.

Replay has its own receipt on the same page, in the section Replay legal basis. It is recorded per domain with a legal basis reference, which is your DPA or DPIA reference. A tenant administrator alone can record it. A Noxtica platform administrator cannot record it for you. Recording does not turn replay on. You turn replay on in Web Analytics & Privacy → Capture Policies.

Web Analytics & Privacy → Consent & Privacy records, for each domain, the legal basis for real-user monitoring, whether visitors must consent and the DNT and GPC policy. The Legal basis list offers ”— none —” and rum_observability. A domain appears in the list when it collects real-user monitoring data, has no legal basis recorded and either does not require consent or overrides DNT and GPC.

Prerequisites

  • The administrator role. Reading the register needs the same permission as recording a basis.
  • A multi-factor method enrolled on your account. Recording, changing, withdrawing and saving a consent decision ask for a fresh check.
  • The decision itself. Settle with your counsel which Article 6(1) basis and, where relevant, which Article 9(2) condition apply to the feature.
  • For hosted identity verification, the basis is recorded on a different page. See Invitations and hosted settings.
  • Replay legal basis is the exception to platform-administrator recording: your own tenant administrator must record it.

Steps

1. Record a basis for a gate

  1. Open Backoffice → Privacy & Legal → Legal Basis Register.
  2. Pick the gate and select Read the disclosure. Read it.
  3. Select Record basis.
  4. Choose the Article 6(1) lawful basis. Choose an Article 9(2) condition when the gate shows “Art. 9 special category” or the dialog marks it required.
  5. If you chose an Article 9(2) condition, type the gate key to confirm the special-category assertion.
  6. Tick the acknowledgement: “I have read the disclosure above and I am recording this lawful basis on behalf of my organisation as controller.”
  7. Submit and complete the step-up check.

2. Change or withdraw a basis

  1. On the gate, select Change basis or Withdraw.
  2. Enter the reason. The limit is 500 characters.
  3. For a change, choose the new basis and acknowledge the current disclosure. When a newer disclosure was published, processing that depends on the newer text stays off until you do.
  4. Select History to see every version with its status, bases, actor, role, times and reasons.
  1. In the same page, scroll to Replay legal basis.
  2. Select the domain.
  3. Enter the real DPA or DPIA reference in Legal basis reference (DPA / DPIA).
  4. Read the disclosure, tick the acknowledgement and select Record legal basis.
  5. To change it later choose Replace the active basis. To stop replay capture on that domain choose Revoke the active basis.
  6. Turn replay on in Web Analytics & Privacy → Capture Policies.

A reference that is empty or contains the text “not supplied” counts as a placeholder. While the reference is a placeholder, Backoffice refuses to arm replay or loosen masking when the result uses masking looser than strict or turns off required consent.

  1. Open Web Analytics & Privacy → Consent & Privacy. Domains that still need a decision are listed.
  2. Choose the Legal basis or leave it as ”— none —”.
  3. Turn Requires consent on or off. Without a legal basis, you must require consent.
  4. Choose the DNT/GPC policy: Honor or Documented override. A documented override needs the legal basis and the acknowledgement “I acknowledge this domain overrides DNT/GPC on an approved legal basis.”
  5. Select Save decision and complete the step-up check. The domain leaves the list.

Verify it works

  • The gate shows “Asserted” with a receipt line such as “Article 6(1): … · receipt v1 · recorded by …”.
  • History lists the new version, and a withdrawn version shows “Withdrawn” with your reason.
  • The audit log shows tenant_legal_basis_asserted, tenant_legal_basis_superseded or tenant_legal_basis_revoked. A consent decision shows domain_rum_privacy_updated.
  • With a receipt in place, enabling replay on the domain is no longer refused for a missing receipt. Without one, Backoffice answers that no active session_replay legal-basis receipt exists for the domain and that nothing was changed.
  • Consent & Privacy shows “No domain has an unresolved consent or privacy decision.”

Troubleshooting

SymptomCauseFix
Enabling replay fails with replay_receipt_required.No active Replay legal basis exists for the domain.Record it in Legal Basis Register → Replay legal basis, then enable replay again.
Replay save fails with legal_basis_placeholder (HTTP 409).The active reference is empty or says “not supplied”.Replace the active basis with the real DPA or DPIA reference.
Replay save fails with replay_receipt_validation_unavailable (HTTP 503).The receipt check could not be completed. Nothing changed.Retry later.
Record basis is blocked with a message about the disclosure.No disclosure is published in your language, or its digest does not match.Switch the Backoffice language to one with a published disclosure. If the digest message persists, report it.
Recording is refused with asserting_role_required (HTTP 403).Your role is neither tenant administrator nor platform administrator.Ask a tenant administrator of your workspace to record it.
Recording fails with already_active (HTTP 409).A basis is already active for the gate.Use Change basis.
Recording fails with disclosure_mismatch (HTTP 409).The page you loaded is stale or the text changed.Reload and record again. Nothing was recorded.
The consent decision is rejected: “Choose a legal basis, or turn on Requires consent.”Capturing without consent needs an approved basis.Choose rum_observability or turn on Requires consent.
The consent decision is rejected for a documented override.An override needs a legal basis and the acknowledgement.Choose the basis, tick the acknowledgement, or set the policy back to Honor.
Hosted verification returns kyc_legal_basis_receipt_required.No active hosted-capture basis exists for your organisation.Record it under KYC Invitations → Settings.