---
name: Ethical Dark-Pattern & Trust Audit
description: Audits a UI/UX flow for misleading visuals, hidden terms, coerced consent, and other brand-trust-damaging dark patterns, then prescribes high-transparency trust-design fixes measured against a private-banking service standard and international rules (FTC dark-pattern guidance, GDPR consent). A design-level review that cites the relevant rule for each finding and routes legal determinations to counsel. For designers, product, and trust & safety.
audience: designer · product · trust & safety
---

# Ethical Dark-Pattern & Trust Audit

## What this is

A structured pass over a flow to find where the design misleads: fake urgency, sneak-into-basket, hidden or buried terms, confirm-shaming, asymmetric consent, forced continuity, obstructed cancellation. For each finding it names the pattern, cites the rule it likely bumps against, and prescribes a transparent alternative held to a high-net-worth service standard — the discretion, clarity, and respect a private-banking relationship implies, applied to a mass-market screen.

## What this is NOT

Not a compliance certification and not a legal determination. It flags design-level findings and cites the relevant rule (FTC guidance on dark patterns, GDPR consent requirements) as context, but whether a specific practice is unlawful is a call for qualified counsel — that routes out. The private-banking standard is used only as a transparency benchmark; this method is not affiliated with UBS or any bank, and reproduces no proprietary material. It does not replace real user testing of comprehension.

## Method

1. **Map the decision points.** List every place the user commits — consents, subscribes, pays, shares data, cancels — because dark patterns cluster where money, data, and exits are.
2. **Test the visuals for honesty.** Check that emphasis, colour, and default selection point to the user's interest, not against it; a decline option hidden in grey text is a finding.
3. **Surface the hidden terms.** Verify price, renewal, commitment, and data use are legible before commitment — not buried, not post-click, not in a scroll trap.
4. **Audit consent symmetry.** Opting out must be as easy as opting in; pre-ticked boxes, roach-motel signup, and confirm-shaming are cited against GDPR consent and FTC guidance.
5. **Walk the exit.** Cancellation must be reachable and as simple as signup; an obstructed or hidden cancel path is flagged (FTC click-to-cancel context).
6. **Apply the private-banking benchmark.** For each finding, ask whether a discreet, client-first advisor would present it this way, and prescribe the transparent version as the fix.
7. **Cite the rule, name the fix.** Record each finding with the pattern name, the rule it references, severity, and a concrete transparent alternative — separating design judgment from legal claim.
8. **Route the legal calls.** Where a finding turns on whether something is lawful, mark it for counsel rather than asserting a verdict.

## Quality bar

Every finding names the dark-pattern type and cites its rule (FTC guidance / GDPR consent) · consent and cancellation symmetry are both tested · hidden terms are checked for pre-commitment legibility · fixes are transparent alternatives, not disclaimers bolted onto the trick · legal determinations are routed to counsel, never asserted · the transparency benchmark is applied, not just invoked.

## Guardrails & escalation

This is a design-level audit, not a compliance certification or legal opinion; whether a practice violates the FTC Act, GDPR, or any statute is a determination for qualified counsel, and those questions route out with the cited rule attached. The private-banking standard is a transparency benchmark only — not affiliated with UBS or any bank. Comprehension findings should be confirmed with real user testing; this review reduces trust risk but does not eliminate it or guarantee any regulatory outcome.

## References

- Catalogue: https://edwson.com/consumer-design-system.html · Contracts: https://edwson.com/cds/components.json · Agent brief: https://edwson.com/cds/AGENTS.md
- Related within this kit: CDS dark-pattern audit, the user-journey & friction map (trust dips), and CDS UX writing. Legal questions route to counsel.