Summary
BezwaarLegalHoldListener never placed a legal hold for its entire life (root cause and fix: #693). Fixing it forward does not repair the cases that passed through a bezwaar/beroep proceeding while the control was dead.
Those cases are, right now, missing the legal hold that archiving law requires, and are therefore destruction-eligible when they should be suspended.
Evidence
On the development instance, after the #693 fix was verified working:
|
count |
case objects |
348 |
bezwaar proceedings |
22 |
| cases carrying a legal hold |
1 (the one created by the #693 positive control) |
So 21 proceedings on that instance alone produced no hold. Production numbers are unknown and need to be measured before deciding on remediation scope.
What is needed
- Quantify — per environment, count cases that have (or ever had) an open
bezwaar / objection / beroep proceeding and carry no _retention.legalHold.
- Decide the rule for "still open" — a proceeding with a matching
bezwaarDecision / appealDecision is closed, and backfilling a hold on it and immediately releasing it may be the wrong outcome. The audit history matters here: a hold that was never placed should probably not be back-dated as if it had been.
- Backfill the still-open ones, with a reason string that makes the remediation visible rather than indistinguishable from a contemporaneous hold.
- Check whether anything was actually destroyed while unprotected. This is the part that decides whether this is a housekeeping task or an incident.
Why not in #693
#693 is a small, provable forward fix with a live positive control. Backfill is a data-remediation programme with its own risk profile (it writes to historical records and to the retention audit trail), and it needs the production numbers from step 1 before a safe rule can be written. Bundling them would make neither reviewable.
Related
Summary
BezwaarLegalHoldListenernever placed a legal hold for its entire life (root cause and fix: #693). Fixing it forward does not repair the cases that passed through a bezwaar/beroep proceeding while the control was dead.Those cases are, right now, missing the legal hold that archiving law requires, and are therefore destruction-eligible when they should be suspended.
Evidence
On the development instance, after the #693 fix was verified working:
caseobjectsbezwaarproceedingsSo 21 proceedings on that instance alone produced no hold. Production numbers are unknown and need to be measured before deciding on remediation scope.
What is needed
bezwaar/objection/ beroep proceeding and carry no_retention.legalHold.bezwaarDecision/appealDecisionis closed, and backfilling a hold on it and immediately releasing it may be the wrong outcome. The audit history matters here: a hold that was never placed should probably not be back-dated as if it had been.Why not in #693
#693 is a small, provable forward fix with a live positive control. Backfill is a data-remediation programme with its own risk profile (it writes to historical records and to the retention audit trail), and it needs the production numbers from step 1 before a safe rule can be written. Bundling them would make neither reviewable.
Related