Internet-Draft vCon Consent Attachment July 2025
McCarthy-Howe & Lasker Expires 8 January 2026 [Page]
Workgroup:
Virtualized Conversations
Internet-Draft:
draft-vcon-consent-00
Published:
Intended Status:
Informational
Expires:
Authors:
T. McCarthy-Howe
Strolid, Inc.
S. Lasker

Voice Conversation (vCon) Consent Attachment

Abstract

This document defines a consent attachment type for Voice Conversations (vCon), establishing standardized mechanisms for recording, verifying, and managing consent information within conversation containers. The consent attachment addresses privacy compliance challenges through structured metadata including consenting parties, temporal validity periods, and cryptographic proof mechanisms.

The specification defines the mandatory and optional fields for consent attachments, including expiration timestamps, party references, dialog segments, and consent arrays. It supports granular consent management through purpose-based permissions and integrates with the AI Preferences vocabulary for automated processing systems. The attachment type incorporates SCITT (Supply Chain Integrity, Transparency, and Trust) for cryptographic transparency and provides integration patterns for consent ledger services.

Key features include automated consent detection during conversation processing, auditable consent records with cryptographic proofs, support for consent revocation through superseding statements, and integration with existing privacy regulations. The consent attachment enables organizations to maintain compliance while providing sufficient structure for automated processing and verification of consent throughout the vCon lifecycle.

About This Document

This note is to be removed before publishing as an RFC.

The latest revision of this draft can be found at https://example.com/LATEST. Status information for this document may be found at https://datatracker.ietf.org/doc/draft-vcon-consent/.

Discussion of this document takes place on the Virtualized Conversations Working Group mailing list (mailto:vcon@ietf.org), which is archived at https://mailarchive.ietf.org/arch/browse/vcon/. Subscribe at https://www.ietf.org/mailman/listinfo/vcon/.

Source for this draft and an issue tracker can be found at https://github.com/howethomas/vcon-howe-vcon-consent.

Status of This Memo

This Internet-Draft is submitted in full conformance with the provisions of BCP 78 and BCP 79.

Internet-Drafts are working documents of the Internet Engineering Task Force (IETF). Note that other groups may also distribute working documents as Internet-Drafts. The list of current Internet-Drafts is at https://datatracker.ietf.org/drafts/current/.

Internet-Drafts are draft documents valid for a maximum of six months and may be updated, replaced, or obsoleted by other documents at any time. It is inappropriate to use Internet-Drafts as reference material or to cite them other than as "work in progress."

This Internet-Draft will expire on 8 January 2026.

Table of Contents

1. Introduction

Voice conversations often contain sensitive information that requires proper consent management. This document defines a consent attachment type for Virtualized Conversations (vCon) that enables automated consent detection, structured consent recording, and proof mechanisms for compliance with privacy regulations.

A vCon (Virtualized Conversation) is a standardized container format for storing conversation data, including metadata, participants, and conversation content. vCons support extensible attachments that can carry additional structured data related to the conversation. These attachments enable the association of various types of information with the conversation, such as transcripts, analytics, or consent records.

The consent attachment type provides a standardized mechanism for recording and managing consent information within vCon containers. This attachment captures essential consent metadata including the consenting party, the specific dialog or conversation segment covered by the consent, temporal validity periods, and any associated proof mechanisms. By embedding consent information directly within the vCon structure, implementations can maintain the integrity of the consent record and ensure it remains associated with the relevant conversation data throughout the lifecycle of the vCon.

The consent attachment addresses key privacy and compliance challenges faced by organizations handling voice conversations. It enables automated consent detection during conversation processing, provides auditable consent records, and supports regulatory compliance through structured consent management. The attachment type is designed to be flexible enough to accommodate various consent models while providing sufficient structure to enable automated processing and verification.

2. Terminology

The key words "MUST", "MUST NOT", "REQUIRED", "SHALL", "SHALL NOT", "SHOULD", "SHOULD NOT", "RECOMMENDED", "NOT RECOMMENDED", "MAY", and "OPTIONAL" in this document are to be interpreted as described in BCP 14 RFC2119 [RFC8174] when, and only when, they appear in all capitals, as shown here.

2.1. Core Terms

Consent: Any freely given, specific, informed, and unambiguous indication of the data subject's wishes by which they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to them [GDPR].

Data Subject: The identified or identifiable natural person to whom personal data relates [GDPR]. Also referred to as "consumer" in some jurisdictions [CCPA].

Data Controller: The natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data [GDPR].

Data Processor: A natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller [GDPR].

Personal Data: Any information relating to an identified or identifiable natural person [GDPR].

Processing: Any operation or set of operations performed on personal data [GDPR].

2.2. vCon-Specific Terms

vCon: A standardized container for conversational information, including metadata, participants, dialog content, analysis, and attachments [I-D.draft-ietf-vcon-vcon-container].

vCon Instance: A vCon populated with data for a specific conversation [I-D.draft-ietf-vcon-vcon-container].

vCon Instance Version: A single version of an instance of a conversation, which may be modified to redact or append additional information [I-D.draft-ietf-vcon-vcon-container].

Party: An observer or participant to the conversation, either passive or active [I-D.draft-ietf-vcon-vcon-container].

Dialog: The captured conversation in its original form (e.g., text, audio, or video) [I-D.draft-ietf-vcon-vcon-container].

Analysis: Analysis, transformations, summary, sentiment, or translation typically of the dialog data [I-D.draft-ietf-vcon-vcon-container].

Attachment: A data block either included or referenced in a vCon [I-D.draft-ietf-vcon-vcon-container].

2.4. Technical Terms

SCITT: Supply Chain Integrity, Transparency, and Trust - a protocol for maintaining append-only transparency ledgers [I-D.draft-ietf-scitt-scrapi-05].

SCRAPI: SCITT Receipt API - the interface for interacting with SCITT Transparency Services [I-D.draft-ietf-scitt-scrapi-05].

COSE: CBOR Object Signing and Encryption - a standard for creating and processing signed, encrypted, and MACed objects [RFC8949].

COSE Sign1: A COSE structure containing a single signature [RFC8949].

AI Preferences Vocabulary: A standardized vocabulary for expressing preferences related to automated processing systems [I-D.draft-ietf-aipref-vocab-01].

Clock Skew: The difference in time between different systems, which must be accounted for when validating temporal constraints.

Referential Integrity: The consistency of references between consent attachments and the vCon elements they reference.

Data Minimization: The principle of limiting personal data collection to what is necessary for the specified purpose [GDPR].

Privacy by Design: The principle of embedding privacy considerations into the design and architecture of systems and processes [NIST-PRIVACY].

2.5. Regulatory Terms

GDPR: General Data Protection Regulation - the primary data protection law in the European Union [GDPR].

CCPA: California Consumer Privacy Act - a state statute intended to enhance privacy rights and consumer protection for residents of California [CCPA].

HIPAA: Health Insurance Portability and Accountability Act - a US law that provides data privacy and security provisions for safeguarding medical information [HIPAA].

Right to be Forgotten: The right of data subjects to have their personal data erased [GDPR].

Right of Access: The right of data subjects to obtain confirmation of whether their personal data is being processed and access to that data [GDPR].

Right of Rectification: The right of data subjects to have inaccurate personal data corrected [GDPR].

Right of Portability: The right of data subjects to receive their personal data in a structured, commonly used, machine-readable format [GDPR].

Lawful Basis: One of the six legal grounds for processing personal data under GDPR: consent, contract, legal obligation, vital interests, public task, or legitimate interests [GDPR].

3. Requirements

3.3. Temporal Validity and Expiration

The "expiration" field MUST contain a timestamp in RFC3339 format indicating when the consent becomes invalid. Implementations MUST compare the current time against this expiration timestamp and SHALL reject expired consent attachments.

The expiration timestamp MAY be set to null to indicate indefinite consent duration, as defined by local policy or applicable regulations. When the expiration field is null, the consent is considered valid indefinitely until explicitly revoked. However, implementations SHOULD provide mechanisms for periodic consent revalidation even when indefinite consent is granted.

When processing consent attachments, implementations MUST account for clock skew and SHOULD allow for reasonable time differences between systems. The acceptable clock skew tolerance SHOULD be configurable but MUST NOT exceed 5 minutes by default.

3.4. Terms of Service Integration

The "terms_of_service" field MUST contain either a URI reference to the applicable terms of service document or an embedded terms object. When using URI references, implementations MUST support HTTPS URLs and SHOULD support content integrity verification through cryptographic hashes.

The terms of service reference MUST be immutable for the lifetime of the consent attachment. If terms of service change, a new consent attachment MUST be created rather than modifying the existing reference.

Implementations SHOULD maintain a local cache of terms of service documents to ensure availability during consent verification. The cache SHOULD respect HTTP cache control headers when fetching terms documents via URI.

3.5. Party and Dialog References

The "party" field MUST contain a zero-based integer index referencing an entry in the vCon parties array. Implementations MUST validate that the referenced party index exists in the vCon and SHOULD verify that the party has authority to grant consent for the specified dialog.

The "dialog" field MUST contain a zero-based integer index referencing an entry in the vCon dialog array. Multiple consent attachments MAY reference the same dialog entry to represent consent from different parties or for different purposes.

Implementations MUST maintain referential integrity between consent attachments and the referenced vCon elements. When a vCon is modified through redaction or amendment, consent attachment references MUST be updated accordingly or the consent MUST be invalidated.

3.6. Status Monitoring and Intervals

The "status_interval" field MUST specify the maximum time interval, in seconds, between consent status verifications. Implementations MUST perform consent status checks at least as frequently as specified by this interval.

The status interval MUST be a positive integer value. A status interval of zero indicates that consent status MUST be verified on every access to the associated dialog content.

3.8. Cryptographic Proof Requirements

The "proof" field MUST contain an array of proof objects that provide cryptographic evidence of valid consent. Each proof object MUST include a "type" field specifying the proof mechanism and a "value" field containing the proof data.

Proof objects MAY include various types of evidence: - Dialog-based proofs: Consent statements or confirmations given verbally or textually within the conversation dialog itself - External document proofs: Signed consent forms, terms of service agreements, or other legal documents referenced by URL or embedded content - External site proofs: Consent granted through web interfaces, mobile applications, or other external systems that provide cryptographic attestation

Implementations MUST support digital signature proofs using algorithms specified in the IANA COSE Algorithms registry [COSE-ALG]. The proof SHOULD include a timestamp indicating when the consent was granted and MUST include a reference to the consenting party's cryptographic identity.

When multiple proofs are present, implementations MUST verify all proofs and SHALL reject the consent attachment if any proof fails validation. The proof verification process MUST include validation of the signing key authority and certificate chain when applicable.

Proof objects MAY reference external proof data to minimize consent attachment size. When external references are used, implementations MUST verify the integrity of externally referenced proof data using cryptographic hashes included in the proof object.

3.11. Privacy and Data Minimization

Consent attachments MUST implement data minimization principles by including only information necessary for consent verification and audit purposes. Personal information SHOULD NOT be duplicated in consent attachments when it is already available in the referenced vCon elements.

The consent attachment design MUST support privacy-preserving verification mechanisms that allow consent validation without exposing sensitive personal information to all parties in a consent verification workflow.

Implementations SHOULD support consent attachment redaction techniques that allow sensitive consent details to be removed while maintaining the ability to verify that valid consent was originally present.

3.12. Error Handling and Validation

Implementations MUST validate consent attachment syntax according to the JSON schema defined in this specification. Malformed consent attachments MUST be rejected with appropriate error messages indicating the specific validation failures.

When consent validation fails, implementations MUST NOT process the associated dialog content and SHOULD log the failure for audit purposes. The error handling process MUST distinguish between temporary failures (such as network timeouts during ledger verification) and permanent failures (such as invalid cryptographic proofs).

Implementations SHOULD provide detailed error reporting to assist with troubleshooting consent validation issues while avoiding exposure of sensitive information in error messages.

3.13. Interoperability and Versioning

Consent attachments MUST include version information to support evolution of the consent attachment specification. Implementations MUST handle version mismatches gracefully and SHOULD support multiple consent attachment versions during transition periods.

The consent attachment format MUST be designed to support extensions while maintaining backward compatibility with existing implementations. New fields MAY be added to consent attachments but MUST NOT break existing validation logic.

Implementations SHOULD support consent attachment format negotiation when multiple parties exchange vCons with different consent attachment version support.

3.14. Security Considerations

All consent attachments MUST be integrity protected using the vCon signing mechanisms. Consent attachments containing sensitive information SHOULD be encrypted when the vCon is transmitted outside secure environments.

Implementations MUST protect consent ledger communications using TLS and SHOULD implement additional authentication mechanisms to prevent unauthorized consent status queries or modifications.

The consent attachment design MUST prevent replay attacks and consent forgery through appropriate use of timestamps, nonces, and cryptographic binding to the specific vCon instance and dialog content.

The key words "MUST", "MUST NOT", "REQUIRED", "SHALL", "SHALL NOT", "SHOULD", "SHOULD NOT", "RECOMMENDED", "NOT RECOMMENDED", "MAY", and "OPTIONAL" in this document are to be interpreted as described in BCP 14 [RFC2119] [RFC8174] when, and only when, they appear in all capitals, as shown here.

{
  "expiration": "2026-01-02T12:00:00Z",
  "terms_of_service": "https://example.com/terms",
  "party": 0,
  "dialog": 0,
  "status_interval": "30d",
  "consent_ledger": "https://ledger.example.com/consent/123",
  "proof": [
    {
      "timestamp": "2025-01-02T12:15:30Z",
      "type": "verbal_confirmation"
    },
    {
      "url": "https://example.com/consent-form.pdf",
      "type": "external_asset"
    }
  ],
  "consents": [
    {
      "value": true,
      "consent": "recording"
    },
    {
      "value": true,
      "consent": "transcription"
    },
    {
      "value": true,
      "consent": "analysis"
    }
  ]
}

3.15. Attachment Fields

3.15.1. Required Fields

  • expiration: ISO 8601 timestamp indicating when consent expires

  • party: Index of the party in the vCon parties array

  • dialog: Index of the dialog in the vCon dialog array

  • consents: Array of consent objects with value and consent type

3.15.2. Optional Fields

  • terms_of_service: URL to the terms of service document

  • status_interval: Duration string (e.g., "30d") for status check intervals

  • consent_ledger: URL to external consent ledger for audit purposes

  • proof: Array of proof objects supporting the consent

3.17. Proof Objects

Proof objects provide evidence of consent and MAY contain:

  • timestamp: ISO 8601 timestamp when consent was given

  • type: Proof type identifier (e.g., "verbal_confirmation", "external_asset")

  • url: URL to external proof document (for external_asset type)

4. IANA Considerations

4.1. vCon Attachment Type Registration

This document requests IANA to register the following vCon attachment type:

  • Type: consent

  • Description: Consent information for voice conversation participants

  • Reference: This document

6. Privacy Considerations

This document describes mechanisms for managing consent information within vCon containers. Implementers MUST ensure compliance with applicable privacy regulations, including but not limited to GDPR [GDPR], CCPA [CCPA], and HIPAA [HIPAA].

The consent attachment provides structured mechanisms for recording and verifying consent, but implementers are responsible for ensuring that their implementations properly respect and enforce data subject rights, including:

Implementers SHOULD follow privacy by design principles [NIST-PRIVACY] and implement appropriate technical and organizational measures to protect personal data throughout the consent lifecycle.

7. Security Considerations

Consent attachments contain sensitive information that requires appropriate security measures:

7.1. Cryptographic Protection

  • All consent attachments MUST be integrity protected using vCon signing mechanisms

  • Consent attachments containing sensitive information SHOULD be encrypted when transmitted outside secure environments

  • Implementations MUST use strong cryptographic algorithms as specified in [COSE-ALG]

7.2. Access Control

  • Implementations MUST implement appropriate access controls for consent data

  • Consent verification SHOULD be performed with minimal privilege

  • Audit logging MUST be implemented for all consent operations

7.3. Network Security

  • All communications with consent ledger services MUST use TLS 1.2 or higher

  • Implementations MUST validate certificate chains and hostnames

  • Implementations SHOULD implement certificate pinning for critical services

7.4. Data Protection

  • Consent data SHOULD be encrypted at rest

  • Implementations MUST implement secure key management

  • Implementations SHOULD support hardware security modules for key storage

7.5. Threat Mitigation

  • Implementations MUST prevent replay attacks through proper use of timestamps and nonces

  • Implementations MUST validate all cryptographic proofs to prevent forgery

  • Implementations SHOULD implement rate limiting to prevent abuse

8. References

8.1. Normative References

[I-D.draft-ietf-aipref-vocab-01]
Keller, P. and M. Thomson, "A Vocabulary For Expressing AI Usage Preferences", Work in Progress, Internet-Draft, draft-ietf-aipref-vocab-01, , <https://datatracker.ietf.org/doc/html/draft-ietf-aipref-vocab-01>.
[I-D.draft-ietf-scitt-scrapi-05]
Birkholz, H. and J. Geater, "SCITT Reference APIs", Work in Progress, Internet-Draft, draft-ietf-scitt-scrapi-05, , <https://datatracker.ietf.org/doc/html/draft-ietf-scitt-scrapi-05>.
[I-D.draft-ietf-vcon-vcon-container]
Petrie, D. and T. McCarthy-Howe, "The JSON format for vCon - Conversation Data Container", Work in Progress, Internet-Draft, draft-ietf-vcon-vcon-container-03, , <https://datatracker.ietf.org/doc/html/draft-ietf-vcon-vcon-container-03>.
[RFC2119]
Bradner, S., "Key words for use in RFCs to Indicate Requirement Levels", BCP 14, RFC 2119, DOI 10.17487/RFC2119, , <https://www.rfc-editor.org/rfc/rfc2119>.
[RFC3339]
Klyne, G. and C. Newman, "Date and Time on the Internet: Timestamps", RFC 3339, DOI 10.17487/RFC3339, , <https://www.rfc-editor.org/rfc/rfc3339>.
[RFC8174]
Leiba, B., "Ambiguity of Uppercase vs Lowercase in RFC 2119 Key Words", BCP 14, RFC 8174, DOI 10.17487/RFC8174, , <https://www.rfc-editor.org/rfc/rfc8174>.
[RFC8949]
Bormann, C. and P. Hoffman, "Concise Binary Object Representation (CBOR)", STD 94, RFC 8949, DOI 10.17487/RFC8949, , <https://www.rfc-editor.org/rfc/rfc8949>.

8.2. Informative References

[CCPA]
State of California, "California Consumer Privacy Act", , <https://oag.ca.gov/privacy/ccpa>.
[COSE-ALG]
IANA, "COSE Algorithms", n.d., <https://www.iana.org/assignments/cose/cose.xhtml>.
[GDPR]
European Union, "General Data Protection Regulation", , <https://gdpr.eu/>.
[HIPAA]
U.S. Department of Health and Human Services, "Health Insurance Portability and Accountability Act", , <https://www.hhs.gov/hipaa/index.html>.
[NIST-PRIVACY]
National Institute of Standards and Technology, "NIST Privacy Framework", , <https://www.nist.gov/privacy-framework>.

Authors' Addresses

Thomas McCarthy-Howe
Strolid, Inc.
S. Lasker