Draft RISK-WP-0002, RISK-WP-0003, RISK-WP-0004
Publication handover (two findings ready, three tasks, one of which is a paragraph); regulatory intake as a working remit rather than one record, carrying RISK-REG-0001's open items; and running the register, where every task traces to something that actually went wrong in week one — grading before reading the inbox, a status the tooling did not know, an id collision, two gradings resting on file comparison because a token expired, and an on-request path nobody has walked. All three are status: proposed. The custodian decides which become active and in what order. Co-Authored-By: Claude Opus 5 <noreply@anthropic.com>
This commit is contained in:
parent
a1961a8f6f
commit
a798a4c771
3 changed files with 404 additions and 0 deletions
125
workplans/RISK-WP-0003-regulatory-intake.md
Normal file
125
workplans/RISK-WP-0003-regulatory-intake.md
Normal file
|
|
@ -0,0 +1,125 @@
|
|||
---
|
||||
id: RISK-WP-0003
|
||||
type: workplan
|
||||
title: "Make regulatory intake a working remit rather than one record"
|
||||
domain: infotech
|
||||
repo: risk-nexus
|
||||
status: proposed
|
||||
owner: the-custodian
|
||||
topic_slug: risk-nexus
|
||||
created: "2026-08-20"
|
||||
updated: "2026-08-20"
|
||||
depends_on_workplans:
|
||||
- RISK-WP-0001
|
||||
---
|
||||
|
||||
# RISK-WP-0003 — regulatory intake
|
||||
|
||||
**Draft.** The half of this repo's remit that `RISK-WP-0001` deliberately did
|
||||
not touch.
|
||||
|
||||
## Goal
|
||||
|
||||
`INTENT.md` says regulation was previously "consulted and discarded" — the same
|
||||
question asked twice and the answer silently expiring. `RISK-REG-0001` is one
|
||||
record against that. Make it a remit: a format that expires, a way for repos to
|
||||
ask, and the open items that record is carrying.
|
||||
|
||||
Done means: the retention question is answered as far as it can be without
|
||||
buying advice, the trigger list for buying advice is ruled, and a repo with a
|
||||
regulatory question knows where to put it.
|
||||
|
||||
## The open items this inherits
|
||||
|
||||
From `RISK-REG-0001` and `RISK-F-0008`, both already written down:
|
||||
|
||||
1. **A defensible retention period per category.** The determination names this
|
||||
as the weakest point in the estate's whole position: supervisory practice
|
||||
accepts audit logging under legitimate interest and then asks how long, and
|
||||
"we keep audit because it is audit" is the form that fails.
|
||||
2. **`audit-core`'s co-residency horizon.** At `P1` the real erasure horizon is
|
||||
the maximum across every co-resident on `platform-pg`, not the declared
|
||||
value. An infrastructure fact is doing load-bearing work in a legal position,
|
||||
which is an uncomfortable place for it to be. Blocked on `audit-core`.
|
||||
3. **The trigger list.** First real person's data, first counterparty contract
|
||||
requiring a stated position, first Art 17 request. Proposed 2026-08-19, not
|
||||
ruled.
|
||||
|
||||
## Tasks
|
||||
|
||||
### T01 — Rule the trigger list
|
||||
|
||||
```task
|
||||
id: RISK-WP-0003-T01
|
||||
status: todo
|
||||
priority: high
|
||||
```
|
||||
|
||||
Custodian decision. Cheap, and it is what stops the estate either buying advice
|
||||
it does not need or discovering it needed it. Until it is ruled, `RISK-F-0008`
|
||||
stays escalated as `partially-answered`.
|
||||
|
||||
### T02 — Retention periods per category
|
||||
|
||||
```task
|
||||
id: RISK-WP-0003-T02
|
||||
status: todo
|
||||
priority: high
|
||||
```
|
||||
|
||||
State a period and a reason per category in `RISK-REG-0001`, or state plainly
|
||||
that the estate cannot yet and why. The second is an acceptable outcome and a
|
||||
better record than a number nobody can defend.
|
||||
|
||||
Depends on `audit-core` answering the co-residency horizon, which has been
|
||||
asked for. If they cannot, that dependency is itself the answer to record.
|
||||
|
||||
### T03 — Intake route for regulatory questions
|
||||
|
||||
```task
|
||||
id: RISK-WP-0003-T03
|
||||
status: todo
|
||||
priority: medium
|
||||
```
|
||||
|
||||
`audit-core` routed theirs by messaging this repo and asking for an owner,
|
||||
which worked. Write that down as the route rather than leaving it as one repo's
|
||||
good instinct: what a regulatory question needs when it arrives, what it gets
|
||||
back, and what this repo will not answer (legal advice, and what the owning
|
||||
repo must therefore do).
|
||||
|
||||
Extend `findings/README.md` or give `docs/regulatory/README.md` the reporter's
|
||||
half. Do not invent an intake system.
|
||||
|
||||
### T04 — Expiry
|
||||
|
||||
```task
|
||||
id: RISK-WP-0003-T04
|
||||
status: todo
|
||||
priority: medium
|
||||
```
|
||||
|
||||
Regulatory records expire; that is why the remit moved here. Put them on the
|
||||
same cadence ladder as findings (`docs/method/review.md`) rather than inventing
|
||||
a second review mechanism — a record that has held still for a quarter is
|
||||
making the same statement a finding at `1q` makes.
|
||||
|
||||
`make check` should report a regulatory record due for a check exactly as it
|
||||
reports a finding.
|
||||
|
||||
## Non-goals
|
||||
|
||||
- **No legal advice.** `INTENT.md`, and the records say so in their own text.
|
||||
- **No survey of every regime that might apply.** Regulation is scoped to rules
|
||||
bearing on data the estate holds, markets it sells into, or obligations it has
|
||||
taken on. A general compliance programme is not this.
|
||||
- **No answering what a repo must therefore do.** That is the owning repo's.
|
||||
|
||||
## Risks
|
||||
|
||||
**The remit becomes a compliance function.** Mitigation: records answer
|
||||
questions that were actually asked, by a repo, with a date.
|
||||
|
||||
**A record states a legal conclusion with false confidence.** Mitigation: every
|
||||
record names where it is weak, and `external_review: none` is a required field
|
||||
rather than an omission.
|
||||
Loading…
Add table
Add a link
Reference in a new issue