Right of reply

Every party identified by name in a finding we intend to publish receives a right of reply before publication. That includes the operator whose storefront took the payment and any institution we attribute the acquiring route to.

The right attaches to publication, not to filing. Where a finding is delivered privately to a client, a scheme or a regulator and is not published by us, the recipient decides what notice its own process requires. We do not publish an entry to the public registry until the window below has run.

Notice is sent once collection is complete and the finding is in its final form — after the payment has settled, the acquiring route has been resolved, and the pack has been assembled. We do not send notice while a question is still open, because a reply to a provisional claim helps nobody.

Notice goes to the address the party publishes for regulatory or compliance correspondence. Where no such address is published, we use the address on the relevant public register. Correspondence is from the desk at once@birdtold.me and is signed by the desk, not by an individual.

The notice sets out, in full, the assertion we intend to publish about that party: the transaction date, the amount, the descriptor as it landed, the declared merchant category code, the vertical actually delivered, and the attribution itself.

It states the evidential basis for each element and identifies the artifacts relied on. It states the deadline, the address for a reply, and what will happen at each of the three outcomes below. It does not disclose the identity of a client, and it does not disclose material that would identify the analyst who made the purchase.

The window is [NUMBER] days from the date the notice is sent. An extension is granted on request where the party states that it is conducting an internal review and gives a date. We grant one extension as a matter of course; a second is a judgement call and is recorded either way.

A reply that supplies new fact is checked against the collected material before anything is published. If it changes the finding, the finding changes; if it corrects a detail, the detail is corrected; if it defeats the finding, the finding is withdrawn and not published. In each case the party is told what we did.

A reply that disputes the finding without supplying new fact is published alongside it. You may mark a reply as confidential, in which case we publish the fact that a reply was received and disputed the finding, and we do not publish its contents.

A reply of any kind is recorded with the date it arrived. Nothing is edited for tone or length. A reply is reproduced as sent, or not at all.

Silence is not treated as agreement and is not characterised as such. If the window closes without a reply, the finding is published with a line stating that notice was given on a stated date and that no response was received by the deadline.

A reply that arrives after publication is still attached to the entry, with its own date, on the same terms as one received in time.

The reply is part of the record, not an appendix to it. Wherever the finding appears — the public registry entry, the evidence pack, and any subsequent restatement of it — the reply, or the fact of a confidential reply, appears with it.

Where a finding has already been supplied to a scheme, a regulator or a client, a reply received afterwards is forwarded to each recipient that received the finding.

A published entry found to be wrong in any material element is corrected on the entry itself. The previous text is not deleted silently: the entry carries the correction, the date of the correction, and what was changed.

Where the attribution itself no longer holds, the entry is marked withdrawn rather than removed, so that anyone who relied on it can see that it was withdrawn and when. Every recipient of the original finding is notified of a correction or a withdrawal.

A request for correction may be made at any time, by any named party, to once@birdtold.me. It is answered whether or not it succeeds.