Legal Consultant

About the Project We are a B2B SaaS company that has recently launched a Voice channel built on top of Twilio's APIs. We provision phone numbers from a shared pool and assign dedicated numbers to customers for inbound and outbound calling via our platform. We need a specialist legal consultant to review our current architecture, assess our liability exposure, and produce actionable sign-offs and contract language — specifically for the US and EU markets. This is not a generalist legal research project. We have already done the research. We need an expert who can read our existing brief, fill the gaps, and produce legally defensible outputs. We need a specialist legal consultant to review our current architecture, assess our liability exposure, and produce actionable sign-offs and contract language — specifically for the US and EU markets. This is not a generalist legal research project. We have already done the research. We need an expert who can read our existing brief, fill the gaps, and produce legally defensible outputs. What you will do? 1. Liability Transfer Architecture Review Review our current Twilio account architecture (single direct account, shared number pool, no ISV/subaccount model) Assess where regulatory and civil liability sits today Recommend the contractual and architectural changes required to transfer liability from the platform to the end customer Benchmark against market standard (Aircall, Zendesk Talk, Freshcaller model) 2. Contract Drafting / Review Voice-specific Acceptable Use Policy (AUP) ToS amendment / clickwrap gate for Voice feature activation Customer indemnification clause covering telecom-specific liability Immediate suspension clause (carrier spam block, TCPA violation, abuse signals) Recording consent allocation and logging requirements B2B-only use restriction for outbound voice Deepfake / AI voice cloning prohibition language Wiretapping / two-party consent state indemnification language India, Swiss FADP, and UK PECR regional carve-outs 3. US Regulatory Sign-offs (primary focus) FCC KYC / KYUP rulemaking implications (April–May 2026 FNPRMs) — originating provider classification STIR/SHAKEN attestation obligations — does the platform need independent RMD registration or can it rely on Twilio's carrier status? TCPA compliance posture — number reassignment (RND/45-day aging), high-volume account scrutiny, B2C restriction Toll-Free Verification (TFV) liability allocation — platform vs end customer CPNI obligations — do they attach given the platform's VoIP provisioning posture? E911 / Registered Location requirements Interconnected VoIP provider classification — yes or no, and what it triggers 18 U.S.C. § 871 / Section 230 analysis — platform conduit defense 4. EU / UK Regulatory Sign-offs (secondary focus) ECS / Number-Based ICS classification under the EECC — does provisioning real PSTN numbers trigger per-member-state registration? EU AI Act readiness — emotion inference from voice (Article 5(1)(f) prohibition, Annex III high-risk classification, Article 50 transparency obligations); deadline August 2, 2026 UK PECR / TPS / CTPS — AUP allocation and ICO exposure GDPR / ePrivacy Directive — call metadata retention, lawful basis, data controller/processor allocation Swiss FADP — sub-processor documentation, individual criminal liability shield for executives 5. Additional Compliance Points ISO 42001 audit readiness — LLM vendor agreements prohibiting training on audio transcripts HIPAA boundary — voice module restriction for BAA accounts vs downstream BAA chain with Twilio Accessibility obligations (ADA / EU EAA) — RTT/TTY on provisioned VoIP numbers