tegwick
9a22a2adc5
Workplan status blocked rather than active: the only remaining task is a custodian decision, and calling that 'active' would be the register claiming progress it is not making. Co-Authored-By: Claude Opus 5 <noreply@anthropic.com>
135 lines
6.1 KiB
Markdown
135 lines
6.1 KiB
Markdown
---
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id: RISK-WP-0003
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type: workplan
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title: "Make regulatory intake a working remit rather than one record"
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domain: infotech
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repo: risk-nexus
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status: blocked
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owner: the-custodian
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topic_slug: risk-nexus
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created: "2026-08-20"
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updated: "2026-08-20"
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depends_on_workplans:
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- RISK-WP-0001
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---
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# RISK-WP-0003 — regulatory intake
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**Draft.** The half of this repo's remit that `RISK-WP-0001` deliberately did
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not touch.
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## Goal
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`INTENT.md` says regulation was previously "consulted and discarded" — the same
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question asked twice and the answer silently expiring. `RISK-REG-0001` is one
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record against that. Make it a remit: a format that expires, a way for repos to
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ask, and the open items that record is carrying.
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Done means: the retention question is answered as far as it can be without
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buying advice, the trigger list for buying advice is ruled, and a repo with a
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regulatory question knows where to put it.
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## The open items this inherits
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From `RISK-REG-0001` and `RISK-F-0008`, both already written down:
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1. **A defensible retention period per category.** The determination names this
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as the weakest point in the estate's whole position: supervisory practice
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accepts audit logging under legitimate interest and then asks how long, and
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"we keep audit because it is audit" is the form that fails.
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2. **`audit-core`'s co-residency horizon.** At `P1` the real erasure horizon is
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the maximum across every co-resident on `platform-pg`, not the declared
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value. An infrastructure fact is doing load-bearing work in a legal position,
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which is an uncomfortable place for it to be. Blocked on `audit-core`.
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3. **The trigger list.** First real person's data, first counterparty contract
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requiring a stated position, first Art 17 request. Proposed 2026-08-19, not
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ruled.
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## Tasks
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### T01 — Rule the trigger list
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```task
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id: RISK-WP-0003-T01
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status: wait
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priority: high
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```
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Custodian decision. Cheap, and it is what stops the estate either buying advice
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it does not need or discovering it needed it. Until it is ruled, `RISK-F-0008`
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stays escalated as `partially-answered`.
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Waiting 2026-08-20, typed rather than open-ended (`docs/method/dependencies.md`): the custodian rules the trigger list, and if nothing arrives by 2026-11-17 the register records the assumption **as an assumption**, which is honest and is not an answer. Carried on `RISK-F-0008`.
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### T02 — Retention periods per category
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```task
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id: RISK-WP-0003-T02
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status: done
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priority: high
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```
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State a period and a reason per category in `RISK-REG-0001`, or state plainly
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that the estate cannot yet and why. The second is an acceptable outcome and a
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better record than a number nobody can defend.
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Depends on `audit-core` answering the co-residency horizon, which has been
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asked for. If they cannot, that dependency is itself the answer to record.
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Completed 2026-08-20 — and completed by applying this repo's own dependency rule to itself. Rather than wait on `audit-core`'s co-residency horizon, `RISK-REG-0001` now states target periods per category with the reasoning: 12 months for operator and agent security records, 3 years to year-end for counterparty transaction evidence, 8 years for accounting vouchers (shortened by the Fourth Bureaucracy Relief Act, flagged as worth confirming), 10 years for books and annual accounts, 6 for commercial letters, and delete for anything with no ground identified.
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They are **targets, not achievements**, and the record says so in its own text: the estate cannot demonstrate any of them while the real erasure horizon is the maximum across every co-resident on `platform-pg`. The gap between stated and achieved is the thing `RISK-F-0008` carries, and it is an infrastructure fact rather than a legal one.
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### T03 — Intake route for regulatory questions
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```task
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id: RISK-WP-0003-T03
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status: done
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priority: medium
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```
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`audit-core` routed theirs by messaging this repo and asking for an owner,
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which worked. Write that down as the route rather than leaving it as one repo's
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good instinct: what a regulatory question needs when it arrives, what it gets
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back, and what this repo will not answer (legal advice, and what the owning
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repo must therefore do).
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Extend `findings/README.md` or give `docs/regulatory/README.md` the reporter's
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half. Do not invent an intake system.
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Completed 2026-08-20. `docs/regulatory/README.md` carries the reporter's half, written from what `audit-core` did correctly before a route existed: the question as a question, what you have already decided that depends on it, what becomes expensive if the answer is no, and what you are **not** asking for. Their "we need an owner, not a legal opinion" is what made the question answerable, and it is now the documented shape.
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### T04 — Expiry
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```task
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id: RISK-WP-0003-T04
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status: done
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priority: medium
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```
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Regulatory records expire; that is why the remit moved here. Put them on the
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same cadence ladder as findings (`docs/method/review.md`) rather than inventing
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a second review mechanism — a record that has held still for a quarter is
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making the same statement a finding at `1q` makes.
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`make check` should report a regulatory record due for a check exactly as it
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reports a finding.
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Closed by reference 2026-08-20. Done under `RISK-WP-0004-T06`: regulatory records ride the findings cadence ladder rather than getting a second review mechanism. `RISK-REG-0001` carries `cadence`, `clean_streak`, `last_checked` and `next_check`, and `make check` reports regulatory records due exactly as it reports findings.
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## Non-goals
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- **No legal advice.** `INTENT.md`, and the records say so in their own text.
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- **No survey of every regime that might apply.** Regulation is scoped to rules
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bearing on data the estate holds, markets it sells into, or obligations it has
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taken on. A general compliance programme is not this.
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- **No answering what a repo must therefore do.** That is the owning repo's.
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## Risks
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**The remit becomes a compliance function.** Mitigation: records answer
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questions that were actually asked, by a repo, with a date.
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**A record states a legal conclusion with false confidence.** Mitigation: every
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record names where it is weak, and `external_review: none` is a required field
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rather than an omission.
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