Independence and institutional firewall

Status: v0.1 Public Draft — normative activation boundary; no commission, independent governance, real-person assessment, or credential authority is operational
Applies to: governance, research, assessment, verification, credentialing, training, employment, staffing, sponsorship, publication, appeals, and public claims
Current steward: LockedIn Labs
Evidence cutoff: September 1, 2026

This document defines how the project must manage the structural conflict created when one organization may train, employ, staff, operate services for, evaluate, and publish claims about the same population. It strengthens the Project Charter, Governance policy, Conflict of Interest Policy, and Benchmark Publication Standard.

The controls below are release gates, not claims of current independence. A policy, committee name, external reviewer, or separate company does not by itself establish impartiality.

1. Decision

The project adopts four conclusions for future-release design:

1. A factual production record, a measured capability profile, and an issued credential or tier are different outputs and require different decision authorities.
2. No official human assessment, result, credential, or tier may be authorized until an external-majority FDE Benchmark Commission is seated and the role, data, funding, appeal, and publication controls in this document are operating.
3. Before any official assessment or credential launch, the Commission must publish a structural-independence decision addressing whether the program will remain within LockedIn Labs, move to a separately governed affiliate or independent entity, or use an external certification body.
4. A separate legal entity is not represented here as a universal scientific or legal requirement. It is a structural option whose necessity depends on intended use, jurisdiction, legal accountability, accreditation strategy, ownership, funding, and the ability of the selected structure to prevent undue influence.

2. What kind of requirement is this?

3. Conflict map

LockedIn Labs may have one or more of these roles:

• benchmark founder, funder, repository steward, and platform operator;
• training designer, instructor, or program provider;
• employer or engagement manager for Forward Deployed Engineers;
• staffing, recruiting, recommendation, or placement service;
• services provider to organizations that may submit evidence or use results;
• author of tasks, rubrics, research, software, marketing, and public claims;
• potential assessor, verifier, credential issuer, or appeals administrator.

These roles create financial, reputational, product, access, and outcome incentives. Disclosure is necessary but insufficient. The operating design must prevent a conflicted role from controlling the affected decision.

4. Staged independence model

Progression is not automatic. A later stage requires a signed evidence packet. Failure of a gate leaves the project at the earlier stage.

5. FDE Benchmark Commission

5.1 Status and purpose

The FDE Benchmark Commission is proposed as the protected decision authority for future human measurement and credentialing. It must not be described as seated, independent, or operational until the public roster and activation receipts are complete.

The Commission does not run LockedIn training, staffing, sales, or delivery. It governs the benchmark interpretation, measurement, result, credential, and correction boundaries.

5.2 Composition

The initial Commission must have seven to nine voting members and satisfy all of the following:

• more than half of all voting seats are held by externally independent members;
• the chair and measurement lead are externally independent;
• at least one voting member brings occupational-measurement or psychometric expertise;
• at least one voting member represents candidates, workers, customers, or the broader public without representing LockedIn or a credential-holder association;
• field and enterprise deployment expertise are represented without allowing a single employer, sponsor, vendor, training provider, or affiliate to predominate;
• LockedIn Labs and its controlled affiliates together hold fewer than half of voting seats and never form an approval majority for a protected decision.

This external-majority rule is a project safeguard. It is stricter than merely having an outside advisor and is not presented as a universal accreditation rule.

5.3 Externally independent member

For the initial policy, a member counts toward the external majority only if the public determination confirms that the member:

• is not a current employee, officer, director, controlling owner, or embedded contractor of LockedIn Labs or a controlled affiliate;
• has not received material employment, board, retainer, staffing, training, or consulting compensation from those entities during the prior 24 months;
• is not currently being trained, assessed, placed, represented, or staffed by LockedIn;
• does not supervise or report to a person in those categories;
• has no close family, controlling financial, or outcome-contingent relationship that creates a reasonable appearance of dependence;
• can act without direction from a sponsor, employer, vendor, or commercial operating team in the matter.

The 24-month period is an initial project policy, not a scientific constant or legal definition. A public RFC may change it prospectively. An exception may permit service, but the member does not count toward the external majority for affected matters.

Payment for ordinary Commission service is a narrow exception to the compensation lookback. Fixed, market-reasonable compensation and reimbursement do not by themselves make an otherwise eligible member affiliated when all of the following are true: the schedule is approved in advance by an external-member majority; it applies on the same disclosed basis to comparable Commission roles; it is not contingent on attendance at a particular vote, position taken, pass rate, tier distribution, issuance, placement, adoption, sponsor renewal, or commercial result; it buys no employment, consulting, staffing, training, sales, or delivery service outside the Commission mandate; and the payer, amount or range, and terms are public. Renewal, removal, or future work cannot be conditioned on a member's vote. Any compensation outside this exception remains subject to the normal lookback and conflict determination.

5.4 Appointment, term, and removal

Before the founding appointments are effective, the project must publish:

• an open role description and competency matrix;
• the nomination and selection process;
• candidate qualifications, affiliations, funding relationships, and conflict determinations;
• a public-comment period and response to material objections;
• term, voting status, confidentiality boundary, and compensation;
• the authority that confirmed each appointment.

Founding appointments are independently confirmed by a temporary Founding Appointments Panel of three to five voting members. Every panel member must satisfy the external-independence definition, cannot be a Commission nominee, and must publish the same affiliation, compensation, and conflict disclosures required of a Commission member. The panel must include occupational-measurement or credentialing expertise and an affected-person or public-interest perspective. LockedIn may convene the published process and nominate candidates, but it cannot sit on the panel, direct its deliberations, substitute a rejected nominee, or override its recorded decision. Confirmation requires two-thirds of the full, non-recused panel, including affirmative votes from both required perspectives. The panel expires when it publishes the founding roster, individual determinations, objections and responses, and its signed confirmation record.

After the founding Commission is seated, successors are appointed by the Commission. An external-majority nominations committee runs the open process and recommends a candidate; appointment requires two-thirds of all eligible, non-recused Commission members and an affirmative majority of the eligible external members. A nominee cannot vote on their own appointment. LockedIn, a sponsor, or a commercial operating team has no veto, replacement, or unilateral appointment right.

Terms are two years and should be staggered. No member serves more than two consecutive full terms without a public supermajority exception. Once the Commission is seated, LockedIn cannot unilaterally remove an external member. Removal for cause requires notice, an opportunity to respond, an external-member supermajority, and a public non-sensitive rationale.

A resignation, death, incapacity, removal, or disqualifying affiliation creates a vacancy; it does not convert the seat, reduce the required external share, or give the founder an appointment right. The secretary must publish the vacancy and succession timetable within 14 days, and the nominations committee must ordinarily open the successor process within 30 days. An external seat must be filled by an externally independent successor. The remaining external members may select an eligible external member as interim chair or measurement lead, but an interim officer has no authority beyond the member's existing vote and the published office duties. The vacancy and every interim designation remain public until the successor takes office.

5.5 Protected decisions

The Commission retains or delegates through a published, non-conflicted charter the final authority for:

• construct, job-analysis, blueprint, interpretation, and intended-use changes;
• official scoring policy, critical floors, uncertainty, thresholds, tiers, and standard setting;
• official task-form activation or retirement and material evaluator policy;
• authorization of any human-only, model-only, or human-with-AI comparability claim;
• rater and adjudicator qualification requirements;
• official assessment, result, verification, credential, suspension, and revocation policy;
• release-specific public claims, credential marks, and verification language;
• appeals-panel appointment and aggregate oversight;
• material corrections, suspension, retraction, and restart decisions;
• the structural-entity path and any independence, certification, or accreditation claim.

A technical, commercial, training, staffing, or sponsor body may recommend but cannot override a protected decision.

5.6 Independent quorum and voting

For every protected decision:

• quorum requires a majority of all eligible, non-recused voting members;
• externally independent members must remain a majority of the eligible, non-recused members and of the affirmative votes;
• official scoring, tier, credential, structural-entity, charter, and independence-claim decisions require two-thirds of eligible, non-recused voting members;
• a loss of external-majority quorum defers the decision; it does not lower the threshold;
• recusals, votes, dissents, and the non-sensitive rationale are recorded.

When a vacancy leaves seven to nine occupied voting seats and all composition rules still hold, the normal quorum applies. If fewer than seven seats are occupied, an interim continuity quorum requires a majority of the occupied seats, at least four eligible non-recused members, and an external majority of both participants and affirmative votes. That interim quorum may open and complete the successor process, preserve records, pay ordinary obligations, and take narrowly necessary suspension, privacy, security, or integrity action; it cannot activate a protected decision, new official output, score, threshold, tier, credential, or independence claim. If external-majority quorum is lost, authority is narrower still: only the successor process and necessary protective suspension or incident action may proceed. No vacancy or interim rule lowers an external-majority or supermajority threshold.

No emergency procedure may activate a new score, threshold, tier, credential, or independence claim.

6. Role, decision, and data firewall

6.1 Required separation

Before real-person operation, the program must assign named accountable owners and access roles for:

1. training and curriculum;
2. recruiting, staffing, sales, and customer success;
3. application and identity operations;
4. evidence custody and verification;
5. task administration;
6. rating and adjudication;
7. calculation and result assembly;
8. credential issuance, suspension, and revocation;
9. appeals and complaints;
10. research analysis and publication;
11. platform engineering and security;
12. governance and release authorization.

The role map must identify prohibited combinations, supervised combinations, access boundaries, approval separation, logs, and substitutes. A person with multiple organizational titles follows the strictest applicable restriction.

6.2 Minimum prohibitions

• A trainer cannot rate, adjudicate, verify, issue, or appeal the result of a person they currently train or trained during the prior 24 months.
• A recruiter, staffing representative, sales lead, or engagement owner cannot review candidate-private evidence, rate a candidate, set a candidate outcome, decide an appeal, or receive a hidden result.
• A person who created or supervised the evidence cannot independently verify that evidence.
• A task or rubric author cannot be the sole approver of the resulting form, thresholds, or material validity claim.
• An original reviewer, manager, or commercial beneficiary cannot decide the appeal.
• Compensation, quotas, promotion, contract value, referral fees, or staffing revenue cannot depend on pass rates, tier distribution, credential issuance, or appeal outcomes.
• Training may explain the public construct, but cannot promise a result, expose controlled cases, or market completion as credential evidence.
• Assessment data cannot enter a staffing, employment, sales, or training system by default. A holder may choose to share an approved public verification object for a stated purpose.
• Affiliated products may link to the public benchmark only with an explicit affiliate disclosure and without implying preferred access, endorsement, or score advantage.

The 24-month trainer cooling-off period is an initial project safeguard. It may be changed prospectively only through a public evidence-and-conflict review; an exception requires a substitute reviewer and cannot permit the trainer to control the affected decision.

6.3 The three output authorities

The project must preserve three distinct decisions. Their proposed data and interpretation contracts are developed in the Outcome Architecture and Shared-Work Research Proposal; that package remains non-authorized research and does not activate any output.

One output cannot silently stand in for another. The same person or team must not hold sole approval over all three layers for a case or release.

6.4 Shared-work battery governance

The proposed Shared Work Challenge Battery introduces additional conflicts because a model provider, agent builder, employer, trainer, participant, task author, or benchmark operator may benefit from a comparison.

Before any comparative finding, the release must disclose condition ownership, model/provider relationships, assistance policy, compute/tool/resource envelopes, task and rubric authorship, rater blinding, exclusions, failures, funding, and analytic discretion. A task author, model provider, participant employer, training provider, or commercial beneficiary cannot be the sole approver of the affected comparison. The Commission must approve any claim that human-only, model-only, and human-with-AI conditions support comparable interpretations; shared scenario content alone does not establish score comparability.

7. Conflict and recusal controls

The public conflict register covers governance and material organizational interests. Protected matter records cover candidate, reviewer, employer, customer, task-author, sponsor, training, staffing, and appeal relationships.

For each protected decision, the secretary records:

• members eligible, recused, absent, and present;
• the conflict basis and determination without unnecessary personal detail;
• private-material access removed after recusal;
• the substitute decision path;
• whether external-majority quorum remained intact;
• the vote, dissent, and approval authority.

Disclosure alone does not restore eligibility. A recused person does not brief, lobby, supervise, draft the rationale, receive controlled materials, or vote, except to provide requested and attributed factual information.

8. Funding and operational autonomy

Before stage I1, the project must publish a funding and support register identifying direct funding, material in-kind support, restrictions, duration, concentration, and sponsor role.

Before stages I2 or I3, the Commission must have:

• an approved operating budget sufficient for non-conflicted measurement review, accessibility, security/privacy review, appeals, correction, and incident response;
• control over the portion of that budget assigned to protected decisions;
• authority to select independent reviewers and appeals personnel without sponsor or commercial-team approval;
• a continuity plan for loss of a material funder;
• compensation rules that prohibit outcome-contingent incentives.

LockedIn may fund the program. Funding does not establish control rights over protected decisions and does not support an “independently funded” claim.

9. Transparency record

Subject to privacy and controlled-case limits, the project publishes:

• Commission roster, biographies, voting status, terms, appointment and removal records;
• independence determinations, affiliations, material compensation policy, conflicts, and recusals;
• charters, delegations, agendas, minutes, votes, dissents, and management responses;
• funding and in-kind support register, sponsor restrictions, and concentration disclosure;
• role-separation matrix and an aggregate access-control assurance record;
• independent-review scope, method, conflicts, findings, response, and disposition;
• release, correction, suspension, appeal, revocation, and incident aggregates;
• the current independence stage and every unmet gate;
• the structural-entity decision and its next review date.

Zero, absent, and blocked states belong in a status or transparency record. They must not be promoted as proof of quality, used as achievement metrics, or presented as the primary value proposition of a landing page.

10. Reserved terminology and “official” gate

The word official is not a synonym for polished, published, internally approved, or operated by LockedIn Labs.

Until stage I3, public materials may use exact negative status statements such as “official numeric scoring is disabled,” but must not use unqualified “official benchmark,” “official FDE score,” “official tier,” or “official credential.”

At stage I3, an authorized use must name:

• the issuer and accountable legal entity;
• the exact benchmark, instrument, scoring-policy, task-form, and release versions;
• the approved output class, population, context, and intended use;
• issue, effective, expiration, suspension, revocation, and verification state;
• the Commission decision and applicable external authority;
• limitations, appeal route, and correction route.

The terms independent, independently validated, certified, accredited, industry standard, and similar trust claims require their own evidence. An external reviewer, external-majority Commission, separate entity, or publication decision does not automatically authorize them.

11. Structural-entity decision framework

Before stage I3, the Commission must publish a signed decision comparing at least these options:

1. a hosted program within LockedIn Labs with protected autonomous decision rights;
2. a separately governed affiliate or subsidiary;
3. an independent nonprofit, foundation, or multi-party consortium;
4. assessment or credential issuance by an external qualified certification body.

The comparison must address:

• legal responsibility, contracting, liability, insurance, and applicable jurisdictions;
• ownership and licensing of the benchmark, data, trademarks, and controlled materials;
• board appointment/removal, protected authority, budget, staff supervision, and information rights;
• training, staffing, employment, customer, sponsor, and vendor conflicts;
• privacy roles, security operations, records custody, subpoenas, incidents, and data-subject rights;
• assessment validity, impartiality, accessibility, complaints, appeals, discipline, renewal, and revocation;
• accreditation or conformity strategy and independent expert interpretation of the applicable requirements;
• transition, continuity, insolvency, dissolution, and successor stewardship;
• cost, operational feasibility, public-benefit rationale, residual risks, and review date.

The decision must include qualified legal, measurement, privacy/security, and credentialing review. If the program remains inside LockedIn, public language must describe the actual autonomy controls and residual affiliate conflict; it cannot say “separate” or “organizationally independent.” If a new entity is created, the project must still prove that funding, appointments, contracts, data, and IP do not preserve effective LockedIn control.

12. Activation receipts

No independence-stage change is complete without a versioned packet containing:

• exact governing documents and effective dates;
• roster, qualifications, affiliations, conflicts, signatures, and term records;
• appointment, removal, quorum, delegation, and voting rules;
• role and data-access matrix with control-test results;
• funding, sponsor, compensation, and continuity records;
• independent review and management response;
• legal/use, privacy, security, accessibility, and measurement approvals applicable to the stage;
• structural-entity decision where required;
• release vote, dissent, artifact manifest, and public claim receipt.

The packet may protect personal, security-sensitive, and controlled-case details, but it must publish a non-sensitive receipt and reason for every withheld category.

13. Suspension and failure

The Commission or a properly constituted independent emergency panel must suspend the affected activity when:

• external-majority quorum is lost for a protected decision;
• an undisclosed material conflict or prohibited data flow is discovered;
• a sponsor, commercial team, employer, trainer, or affiliate attempts to influence a protected outcome;
• the appeal path, security/privacy control, or correction channel becomes unavailable;
• an independence, certification, validation, or accreditation claim exceeds its evidence;
• the issuer, legal responsibility, or structural authority becomes unclear.

Suspension preserves prior records and starts a documented impact review. It does not silently alter a result or erase the conflict history.

14. Source and conformance boundary

This policy is informed by, but does not claim conformance with:

• ISO/IEC 17024:2026, whose public record and contents address legal responsibility, certification decisions, impartiality, organizational structure in relation to education or training, records, appeals, and human oversight of AI-assisted certification;
• the ISO Committee on Conformity Assessment overview, which describes common legal, structural, impartiality, confidentiality, complaints, appeals, and public-information requirements for conformity-assessment bodies;
• the NCCA Standards and accreditation resources, which treat governance autonomy and separation of certification and education as program-quality concerns;
• the NCCA FAQ, which states that a certification board need not be separately incorporated if it can demonstrate autonomy and freedom from undue influence;
• the Standards for Educational and Psychological Testing, the SIOP Principles, and the EEOC Uniform Guidelines for intended-use, validation, fairness, job relevance, records, and selection-procedure considerations.

The public ISO standard summary does not establish that this project must create a separate legal entity. The NCCA FAQ likewise distinguishes separate incorporation from decision autonomy. The applicable legal and accreditation conclusion must be made for the final program design by qualified counsel and, if pursued, the relevant accreditation authority.

Related documents: CHARTER.md · GOVERNANCE.md · CONFLICT_OF_INTEREST.md · SCORING.md · APPEALS.md · Benchmark Publication Standard