Screening isn’t just about who gets approved. It’s about being able to show your work when anyone asks why.
The Defensible Screening Standard (DSS) is a proposal for how our industry can do that.
It’s a shared way to design screening so decisions are lawful, explainable, and audit-ready. Think of DSS as the proof layer that connects policy, people, and systems — so your process can be inspected without exposing consumer data or revealing proprietary scoring.
This is the starting line. DSS is not an approved or recognized standard. It’s a concept I’m putting on the table to invite critique, improvement, and collaboration across operators, vendors, advocates, and public agencies.
The problem DSS wants to solve
Most failures don’t come from one bad tool. They come from the space between tools.
Policy says one thing. Systems say another. People work around both.
That is where disputes multiply, timelines slip, and trust erodes.
What if we aligned on a common structure for screening — not to tell anyone what to decide, but to make it easy to prove how the decision was made?
What DSS proposes (concept)
DSS proposes a small set of controls and evidence artifacts that every screening workflow can produce, regardless of the tech stack. The idea is simple:
- Every request to use consumer data ties to a clear business need.
- Every rule in your criteria has a plain-English rationale.
- Every decision can be reconstructed from inputs, reasoning, and notices.
- Every exception, dispute, or accommodation is documented end to end.
- Every portfolio can run quick outcome checks and adjust with intent.
DSS does not replace your screening tools. It wraps them with process clarity and proof.
What DSS is not
- Not a legal service or legal advice.
- Not a consumer reporting agency.
- Not an endorsement by any regulator or association.
- Not a black-box model that tells you who to accept or deny.
DSS is a shared frame for process + proof.
Decisions remain yours.
Principles behind the proposal
Good Data:
Use trusted, verified sources of truth.
Good People:
Keep human judgment in the loop where it matters.
Good Design:
Build compliance into the workflow, not as an afterthought.
These principles guide how controls are phrased and how artifacts are produced.
How DSS would show up in practice (at a glance)
Imagine each application generating a compact Decision Proof Packet that contains:
- The policy snapshot in effect that day.
- The inputs relied upon and which identifiers were used.
- The reasons actually applied in the decision.
- The notice that was sent, and when.
- Any exceptions, disputes, or accommodations, with outcomes.
With this, there would need to be some kind of portfolio-level dashboard that can answer simple but high-value questions:
- Are adverse-action notices consistent across properties?
- Do public-record items include dispositions before they influence a decision?
- Are exceptions concentrated in a few criteria that need a second look?
- Are outcome patterns hinting at criteria that should be tuned?
These would be the minimum necessary core of DSS. Not new math. Better line of sight.
Why this matters to everyone
Operators & Owners
You get a workflow that holds up when challenged and a repeatable way to train new teams. Your process becomes faster to explain and cheaper to defend.
Screening Vendors & Platforms
You can map your product features to clear controls and provide customers with the artifacts they need, without becoming their policy department.
Advocates & Public Agencies
You gain a transparent view of how decisions are made, which reduces uncertainty and focuses collaboration on facts instead of assumptions.
Investors & Partners
You see how risk is managed in practice — with evidence — not just promises.
The public outline (concept level)
To keep the introduction simple, DSS groups controls into six families. The internal keys use a stable CTRL scheme for traceability across versions.
A) Lawful access & transparency
- CTRL-001 Permissible purpose & certification
- CTRL-002 Identity & match expectations
- CTRL-003 Publishable, business-necessary criteria
B) Accuracy & relevance
- CTRL-004 Individualized assessment for criminal records
- CTRL-005 Reasonable accommodations workflow
- CTRL-006 Consistent adverse-action notices
C) Disputes, corrections & fairness
- CTRL-007 Clear dispute path and re-adjudication
- CTRL-008 Optional pre-decision review window
D) Equal-housing awareness & model governance
- CTRL-009 Outcome snapshots and remediation notes
- CTRL-010 Model or score transparency and guardrails
E) Security, retention & vendors
- CTRL-011 Data retention and proper disposal
- CTRL-012 Information-security program where applicable
- CTRL-013 Vendor oversight and attestations
F) Proof & auditability
- CTRL-014 Decision audit trail and exception logging
The detailed control text, legal anchors, and artifacts stay private while the idea matures with the working group.
What “good” could look like
- A leasing associate can explain a denial in two sentences because the reasons are recorded in plain English and tied to policy.
- A regional manager can export five Decision Proof Packets and answer an auditor’s questions in one meeting.
- A vendor can show, in one page, how their product outputs align with the portfolio’s criteria and proof needs.
- A public agency can understand the decision logic without seeing any consumer PII.
This is not a directive for a specific tool. It’s a proposal for a shared structure.
An open invitation to help shape DSS
The goal is simple: make DSS useful in the real world without creating busywork.
Who would be ideal to join
- Property managers and owners
- Screening vendors and platforms
- Counsel and compliance leaders
- Advocates and public-sector stakeholders
How to express interest
This is still comletely a work in progress, even as an idea and concept. But if you’d be interested in talking with me about it. The best way to get in touch would be to message me on LinkedIn.
https://www.linkedin.com/in/johnnybravo/
Where we go from here
This post is the beginning. I am proposing a structure, listening for feedback, and soon, inviting participation.
If the idea proves valuable, it will evolve in the open, to document what works, and keep the detailed materials with the people who are doing the work.
If you have thoughts — supportive or skeptical — I’d love to hear them.
DAx — Where proof meets process.