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RISK-F-0008 accepted: no external determination, policy set instead

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The triggers survive as what ends the acceptance rather than as what
starts a purchase. Accepted is not closed — it keeps its cadence, and
audit-core's two questions stay open under it.

Co-Authored-By: Claude Opus 5 <noreply@anthropic.com>
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tegwick 2026-08-20 23:36:44 +02:00
parent 7f135f9e0f
commit 674bd41635
2 changed files with 43 additions and 13 deletions
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53
findings/RISK-F-0008-audit-retention-legal-basis-assumed.md
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@ -2,7 +2,7 @@
id: RISK-F-0008
type: finding
title: "The legal basis for retaining audit facts against an erasure request has been assumed, never established"
status: open
status: accepted
reported_by: audit-core
reported_via: audit-core
routed_by: audit-core
@ -29,17 +29,20 @@ publication_subtitle: "The estate retains personal data in audit records on grou
revision: "graded-1"
last_reviewed: "2026-08-20"
review_interval: 6m
escalation: required
escalation: answered
escalation_trigger: 2
escalation_status: partially-answered
escalation_status: answered
accepted_by: the-custodian
accepted_on: "2026-08-20"
accepted_until: "the estate holds a real person's data, or a counterparty requires a stated position"
escalation_answered: "2026-08-20"
escalation_answered_by: the-custodian
escalation_act: rule
decision: "identity in audit records: opaque subject ids preferred, agent identifiers where possible, operator credentials only where necessary, policy decisions tracked to the responsible party; zone-level privacy guarantees may raise the floor"
outstanding: "a defensible retention period per category (waits on audit-core's co-residency horizon), and the trigger list for buying an external answer"
determination: RISK-REG-0001
last_checked: "2026-08-20T10:02:41Z"
next_check: "2026-08-20T10:02:41Z"
last_checked: "2026-08-20T21:36:44Z"
next_check: "2026-08-20T21:36:44Z"
cadence: instant
clean_streak: 0
waiting_on:
@ -49,12 +52,6 @@ waiting_on:
would_change: "a working keyed commitment narrows RISK-REG-0001 to retained-by-obligation categories only"
default: "encrypt-then-hash recorded as the only known route, and the retention period recorded as unstateable"
default_at: "2026-11-17"
- who: the-custodian
what: "rule the trigger list for buying an external determination"
since: "2026-08-19"
would_change: "fixes when the estate stops running on an assumption"
default: "the assumption is recorded in the register as an assumption"
default_at: "2026-11-17"
graded_by: risk-nexus
ruling: RISK-RULING-2026-08-19-C
---
@ -328,3 +325,37 @@ waits on the co-residency horizon, and the trigger list for buying an external
determination. The record is reviewed every 90 days with this finding, or
immediately on any trigger.
- **2026-08-20** — not clean: The determination now exists: RISK-REG-0001 states the grounds per category and names duration as the weak point. Cadence instant → instant; checked again immediately.
## Operator decision — 2026-08-20: no external determination, and a policy set instead
Ruled: **the estate will not buy an external determination while it is
building.** The internal determination (`RISK-REG-0001`) stands as the recorded
position, and the finding moves to `accepted` — deliberately carried, with a
named accepter and a condition that ends it.
That is not the same as the trigger list being rejected. The triggers survive
as what ends the acceptance: a real person's data, or a counterparty requiring
a stated position. What was declined is spending money in advance of either.
**The compensating control is the thing that makes this defensible.** Rather
than defer the question, the operator directed that the estate **define and
keep a set of legal policies for reuse**, because future work contexts will
need specific positions in place and should retrieve them rather than research
them.
`docs/regulatory/policies/` now catalogues thirteen, keyed by activation
condition. Two of them turned out to be **already active and unowned**:
commercial and tax retention (`RISK-POL-0009`), and the e-invoicing receiving
obligation (`RISK-POL-0012`), live since 2025 with no system in the estate
named as the receiving point.
Finding an unnoticed live obligation in the first hour of building the
catalogue is the argument for having built it. The reason this repo exists is
that regulation was previously "consulted and discarded"; a set that answers
"what applies if we do X" before anyone does X is the opposite of that.
**Still open under the acceptance**, and unchanged by this ruling: `audit-core`
on whether a keyed commitment restores erasability, and the `platform-pg`
co-residency horizon that decides whether the stated retention periods are
achievable. An accepted risk still gets checked.
- **2026-08-20** — not clean: Trigger list ruled: no external determination in build mode; accepted with the legal policy set as the compensating control. Cadence instant → instant; checked again immediately.