RISK-WP-0005 T02, T03, T04: intake, the transition, and an honest README
T02: docs/method/intake.md names all four sources INTENT claims and builds the two that had none. An incident files first and grades within the hour, carries first_observed because obligations run from it, sits at instant until it is over, and escalates immediately rather than batched — a 72-hour notification clock outranks the rule that protects the operator's attention. External report has no address anywhere in the estate, and where one lives is policy-nexus's and the custodian's, so it is routed with a proposal rather than invented here. T03: the production transition defined by what is held rather than what was announced — the first moment any system holds real external data, which can happen by accident and cannot be reversed. Declared by the custodian; noticed and asked about by this register. Lists what fires: five re-scores, two acceptances ending, six policies activating. T04: the README no longer claims a surface this repo does not have. Co-Authored-By: Claude Opus 5 <noreply@anthropic.com>
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---
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id: RISK-METHOD-PRODUCTION
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type: method
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title: "The production transition: what expires, and who says when"
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status: proposed
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owner: the-custodian
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drafted_by: risk-nexus
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drafted: "2026-08-21"
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workplan: RISK-WP-0005-T03
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review_interval: 6m
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---
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# The production transition
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Five findings owe a re-score here. One acceptance **expires** here. Several
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dormant legal policies activate here. And until 2026-08-21 nobody had defined
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the event, named who declares it, or told the repos that carry the obligations.
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An acceptance that expires on an undefined event expires on nobody's calendar.
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**Status: `proposed`.** The definition is the custodian's; the plumbing is
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this repo's.
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## Proposed definition
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> **The production transition is the first moment any system in the estate
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> holds, processes or decides about the data of a real external person or
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> tenant.**
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Deliberately not: a launch announcement, a version number, a deployment to a
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cluster named production, or a declaration made in advance. All four can be
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true while nothing real is at stake, and all four can be false on the day
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something is.
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Two consequences worth stating, because they are what make the definition
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usable:
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- **It can happen by accident.** A single real signup, a migrated contact list,
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one counterparty's document sent through a pipeline for testing. Which is
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why it is defined by what is held rather than by what was announced.
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- **It is not reversible.** Deleting the data afterwards does not un-transition
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the estate; it changes the exposure and not the fact that the estate is now
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the kind of thing that holds real data.
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## Who declares it
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The operator, through `the-custodian`. Not this register: `INTENT.md` keeps
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"deciding what canon says" and estate-level facts with the custodian, and a
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risk register that unilaterally declares the estate to be in production has
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appointed itself.
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What this register does is **notice and ask**. Any finding, verification or
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policy check that turns up real external data in a system triggers one question
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to the custodian: *has the transition happened?* The answer is theirs; the
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record is ours.
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## What fires on the day
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| Obligation | Carried by | Count today |
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| --- | --- | --- |
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| Re-score every finding with `production_rescore: true` | this register | 5 |
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| `RISK-F-0007`'s acceptance expires — the unverified tenant boundary stops being carried | this register, escalating | 1 |
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| `RISK-POL-0001`, `0003`, `0004`, `0005`, `0008` activate; `0002` fully | owning repos | 6 policies |
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| `RISK-F-0008`'s acceptance ends — the retention basis stops being an internal determination | this register | 1 |
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`make check` lists the first two under "owed at the production transition"
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today, so the size of the obligation is visible before the day rather than
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discovered on it.
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## How the register hears about it
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Three routes, in order of reliability:
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1. **The custodian says so**, in a message. Preferred, and the only one that is
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also a decision.
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2. **A finding or verification turns up real external data**, and this register
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asks. This is the route that works when nobody remembered to declare.
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3. **A legal policy activates on its own condition** — the accessibility or
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data-subject-rights entries in `docs/regulatory/policies/` fire on facts
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about the world, not on a declaration, and a repo consulting one is evidence
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the transition may have happened.
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Route 2 exists because route 1 is exactly the kind of announcement that gets
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skipped in a busy week, and the estate has already demonstrated (`RISK-POL-0012`)
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that an obligation can be live for nineteen months without anyone noticing.
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## What this document does not do
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It does not schedule the transition, gate it, or require anything before it. In
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build mode a finding is information — that is unchanged. This says only what
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becomes true on a day that will arrive whether or not it is planned.
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