{
  "schema_version": "1.0",
  "source_register": [
    {
      "id": "src-intake",
      "title": "Intake and supplied-records list",
      "version": "Intake baseline",
      "calendar_date": null,
      "approval_status": "Sponsor scope acknowledgment is illustrated; no institutional authorization is recorded.",
      "review_state": "Read in this illustration",
      "content": "Two declared uses are in scope: staff drafting from procedure text and an embedded vendor feature under consideration. No customer or account data is supplied.",
      "limitation": "The list is the supplied starting point, not a complete technology census."
    },
    {
      "id": "src-staff",
      "title": "Staff-use disclosure",
      "version": "Initial disclosure",
      "calendar_date": null,
      "approval_status": "No authorization to send confidential material is supplied.",
      "review_state": "Read in this illustration",
      "content": "Staff report using a public assistant to draft procedure explanations. The assistant runs outside the institution. Staff do not declare which procedure version was used or all text entered.",
      "limitation": "Self-report is incomplete and does not establish data exclusion or full usage coverage."
    },
    {
      "id": "src-procedure-earlier",
      "title": "Earlier controlled procedure",
      "version": "Revision 1",
      "calendar_date": null,
      "approval_status": "A supplied approval record marks this version approved through the institution's procedure-control route. The approver name and calendar date are blank.",
      "review_state": "Excerpt compared in this illustration",
      "content": "A second reviewer must approve an exception before staff act. If an instruction conflicts with the controlled procedure, pause and refer the question to the procedure owner.",
      "limitation": "This excerpt alone does not establish that the full procedure is complete, current or acceptable."
    },
    {
      "id": "src-procedure-later",
      "title": "Later working procedure copy",
      "version": "Revision 2 working copy",
      "calendar_date": null,
      "approval_status": "No approval record or supersession notice is supplied.",
      "review_state": "Excerpt compared in this illustration",
      "content": "Staff may act on a routine exception and notify the second reviewer afterward. The working copy does not say when an exception stops being routine.",
      "limitation": "The higher revision number does not make this working copy the controlling version."
    },
    {
      "id": "src-vendor-proposal",
      "title": "Embedded-feature proposal",
      "version": "Proposal baseline",
      "calendar_date": null,
      "approval_status": "No feature activation approval is supplied.",
      "review_state": "Read in this illustration",
      "content": "The existing platform may include an AI-assisted summary feature. The proposal describes summaries but does not state whether the feature is on by default, which fields it reads, what is retained, or how the institution disables it.",
      "limitation": "A proposal reference is evidence of a claim, not evidence of actual configuration or accepted controls."
    },
    {
      "id": "src-vendor-disclosure",
      "title": "Vendor feature disclosure",
      "version": "Initial disclosure",
      "calendar_date": null,
      "approval_status": "No institutional acceptance is supplied.",
      "review_state": "Read in this illustration",
      "content": "The disclosure refers to service-event metadata and an administrator setting. It does not describe free-text fields, downstream processing, retention, or the effect of switching the setting off.",
      "limitation": "The disclosure leaves data reach and effective disablement unanswered."
    },
    {
      "id": "src-change",
      "title": "Changed vendor feature disclosure",
      "version": "Revised disclosure",
      "calendar_date": null,
      "approval_status": "No institutional acceptance or activation approval is supplied.",
      "review_state": "Read and compared in the follow-up illustration",
      "content": "The revised disclosure says the feature is enabled unless the institution disables it and may read free-text service notes in addition to event metadata. No configuration capture or retention answer accompanies the revision.",
      "limitation": "The supplied change reopens the data-reach and default-setting question; it does not prove the live setting."
    }
  ],
  "coverage_activities": [
    {
      "id": "cov-scope",
      "activity": "Agree the review boundary",
      "what_was_done": "Read the intake baseline and record the two declared uses and supplied materials.",
      "finding": "The engagement is bounded to the supplied records and these two uses.",
      "limit": "No network discovery, system access or institution-wide census was performed."
    },
    {
      "id": "cov-disclosures",
      "activity": "Reconcile use disclosures",
      "what_was_done": "Compare staff-use disclosure with the embedded-feature proposal and vendor disclosure.",
      "finding": "Staff inputs and vendor data reach remain incompletely declared.",
      "limit": "A disclosure does not establish actual behavior."
    },
    {
      "id": "cov-versions",
      "activity": "Reconcile procedure versions",
      "what_was_done": "Compare both supplied excerpts and their approval provenance.",
      "finding": "Secondary-review instructions conflict; only the earlier version has supplied approval evidence.",
      "limit": "No full-procedure acceptance or supersession determination is made."
    },
    {
      "id": "cov-review",
      "activity": "Prepare the reviewer file",
      "what_was_done": "Record observations, open questions, role assignments, recommendation and conditions.",
      "finding": "The board summary explains why feature activation is deferred and staff drafting is limited.",
      "limit": "Preparation does not record a reviewer acceptance or an institutional decision."
    },
    {
      "id": "cov-change",
      "activity": "Review a supplied change",
      "what_was_done": "Retain the baseline and compare a revised vendor disclosure to the initial disclosure.",
      "finding": "Default activation and free-text data reach reopen the affected question.",
      "limit": "The revised disclosure is not a live configuration inspection."
    }
  ],
  "six_column_evidence_rows": [
    {
      "id": "use-staff",
      "use": "Staff drafting of procedure explanations",
      "where_it_runs": "A public assistant outside the institution",
      "data_it_can_touch": "Reported procedure text; full inputs are not disclosed. Customer, member, account and confidential material must be excluded.",
      "owner": "Operations procedure owner",
      "evidence_on_hand": "Staff-use disclosure; earlier controlled procedure; later working copy; supplied approval record for the earlier version",
      "question_still_open": "Which version controls, and can the permitted input boundary be demonstrated?",
      "source_ids": [
        "src-staff",
        "src-procedure-earlier",
        "src-procedure-later"
      ],
      "reviewer_observation": "The excerpts conflict on secondary review. No supersession evidence supports treating the later working copy as controlling. Input disclosure remains incomplete.",
      "review_disposition": "Retain the earlier controlled procedure as the review baseline; resolve conflict before using generated instructions operationally."
    },
    {
      "id": "use-vendor",
      "use": "Embedded AI summary feature in an existing platform",
      "where_it_runs": "The vendor's service; downstream processing is not declared",
      "data_it_can_touch": "Initial disclosure mentions event metadata; free-text reach, retention and downstream access are unresolved.",
      "owner": "Vendor-management owner with IT review",
      "evidence_on_hand": "Embedded-feature proposal and incomplete initial vendor disclosure",
      "question_still_open": "Is the feature enabled by default, what can it read, and does the institution's off setting stop the relevant processing?",
      "source_ids": [
        "src-vendor-proposal",
        "src-vendor-disclosure"
      ],
      "reviewer_observation": "The documents describe a feature but do not establish the live setting or effective off control.",
      "review_disposition": "Do not authorize activation on the supplied evidence; request configuration and data-handling evidence."
    }
  ],
  "conflicting_procedure_excerpts": [
    {
      "source_id": "src-procedure-earlier",
      "excerpt": "A second reviewer must approve an exception before staff act. If an instruction conflicts with the controlled procedure, pause and refer the question to the procedure owner.",
      "approval_state": "A supplied approval record marks this version approved through the institution's procedure-control route. The approver name and calendar date are blank."
    },
    {
      "source_id": "src-procedure-later",
      "excerpt": "Staff may act on a routine exception and notify the second reviewer afterward. The working copy does not say when an exception stops being routine.",
      "approval_state": "No approval record or supersession notice is supplied."
    }
  ],
  "open_questions": [
    {
      "id": "q-procedure",
      "question": "Which procedure version controls?",
      "reason": "The supplied excerpts conflict and the later working copy lacks approval and supersession evidence.",
      "needed_evidence": "Procedure owner's controlling-version confirmation, approval record and explicit treatment of the conflicting instruction.",
      "owner_role": "Operations procedure owner",
      "status": "Open"
    },
    {
      "id": "q-staff-data",
      "question": "What text has staff sent, and what may they send?",
      "reason": "The staff disclosure does not enumerate inputs or demonstrate exclusion of confidential material.",
      "needed_evidence": "A permitted-input rule, a redacted input example and a review of the disclosed usage boundary.",
      "owner_role": "Risk/compliance owner with operations",
      "status": "Open"
    },
    {
      "id": "q-vendor",
      "question": "What can the feature read, and is it effectively off?",
      "reason": "Default behavior, fields, retention, downstream access and effective disablement are not established.",
      "needed_evidence": "Feature-specific handling terms, field list, retention answer and authorized configuration evidence.",
      "owner_role": "Vendor-management owner with IT",
      "status": "Reopened by supplied change"
    },
    {
      "id": "q-return",
      "question": "What evidence would permit a return to the reviewer?",
      "reason": "The recommendation is conditional; no acceptance or institutional authorization is recorded.",
      "needed_evidence": "Completed role actions, reviewed supporting evidence and a separate recorded decision by the authorized institution reviewer.",
      "owner_role": "Risk/compliance owner",
      "status": "Open"
    }
  ],
  "actions": [
    {
      "id": "action-procedure",
      "owner_role": "Operations procedure owner",
      "action": "Confirm the controlling procedure and resolve the secondary-review conflict with an approval or correction record.",
      "due_milestone": "Before any generated procedure instruction is used operationally",
      "calendar_due_date": null,
      "evidence_to_return": "Controlling-version confirmation and approved treatment of the conflicting instruction",
      "status": "Assigned role; completion not asserted",
      "question_ids": [
        "q-procedure"
      ]
    },
    {
      "id": "action-staff",
      "owner_role": "Risk/compliance owner with operations",
      "action": "Define permitted inputs, collect a redacted example, and review the staff-use disclosure before allowing the limited drafting workflow.",
      "due_milestone": "Before the limited staff drafting workflow begins",
      "calendar_due_date": null,
      "evidence_to_return": "Permitted-input rule, redacted input example and documented review",
      "status": "Assigned role; completion not asserted",
      "question_ids": [
        "q-staff-data"
      ]
    },
    {
      "id": "action-vendor",
      "owner_role": "Vendor-management owner",
      "action": "Obtain feature-specific default, field-access, retention, downstream-processing and disablement answers; reconcile the revised disclosure.",
      "due_milestone": "Before feature activation is reconsidered",
      "calendar_due_date": null,
      "evidence_to_return": "Written feature disclosure and handling terms with unresolved items identified",
      "status": "Assigned role; completion not asserted",
      "question_ids": [
        "q-vendor"
      ]
    },
    {
      "id": "action-it",
      "owner_role": "IT owner",
      "action": "Inspect the authorized feature setting and document what the off control covers; use approved synthetic test material if a control test is authorized.",
      "due_milestone": "Before feature activation is reconsidered",
      "calendar_due_date": null,
      "evidence_to_return": "Authorized setting record and any separately authorized control-test result",
      "status": "Inspection and test are requested; neither is claimed completed",
      "question_ids": [
        "q-vendor"
      ]
    },
    {
      "id": "action-board",
      "owner_role": "Risk/compliance owner",
      "action": "Return the evidence and unresolved items to the authorized reviewer, then record any actual decision separately.",
      "due_milestone": "At the next reviewer decision milestone after the evidence actions",
      "calendar_due_date": null,
      "evidence_to_return": "Reviewer observations and a separately completed institution decision record",
      "status": "Reviewer acceptance and institution decision remain blank",
      "question_ids": [
        "q-return"
      ]
    }
  ],
  "retained_baseline": {
    "id": "baseline-review",
    "label": "Retained review baseline",
    "source_ids": [
      "src-intake",
      "src-staff",
      "src-procedure-earlier",
      "src-procedure-later",
      "src-vendor-proposal",
      "src-vendor-disclosure"
    ],
    "recommendation": "Retain the earlier controlled procedure as the baseline. Limit staff drafting to approved generic or redacted procedure material under human review once the input and version conditions are resolved. Keep the embedded feature disabled pending evidence of data reach, defaults and effective disablement.",
    "decision_conditions": [
      "The procedure owner confirms the controlling version and resolves the secondary-review conflict.",
      "Risk/compliance and operations review the permitted-input rule and redacted example; confidential material remains outside the public assistant.",
      "Vendor management supplies complete feature-specific handling answers, and IT provides authorized evidence of the relevant setting and control behavior.",
      "The authorized institution reviewer makes and records the actual decision separately; a source reference or completed checkbox is insufficient."
    ],
    "actual_institution_decision": {
      "decision": null,
      "reviewer": null,
      "owner": null,
      "calendar_date": null
    },
    "retention_note": "Keep the initial source register, excerpts, observations, open questions and recommendation together. The supplied follow-up does not overwrite them."
  },
  "change_event": {
    "id": "change-vendor-disclosure",
    "trigger": "A revised vendor feature disclosure is supplied after the baseline review.",
    "source_id": "src-change",
    "changed_claim": "The feature is described as enabled unless disabled, with access to free-text service notes as well as event metadata.",
    "affected_question_id": "q-vendor",
    "reopened_question": "What can the feature read, and is it effectively off?",
    "reviewer_observation": "The changed default and broader stated data reach require new configuration and handling evidence. The source change does not prove the live feature is active or that a disable control works.",
    "actions_reopened": [
      "action-vendor",
      "action-it"
    ],
    "baseline_disposition": "Retain the baseline. Add this revision and a follow-up observation; do not silently replace the earlier evidence.",
    "recommendation_after_change": "Continue to defer feature activation and request the revised handling answers plus authorized setting evidence. The staff version-control question stays open on its existing evidence.",
    "actual_institution_decision": {
      "decision": null,
      "reviewer": null,
      "owner": null,
      "calendar_date": null
    }
  },
  "actual_institution_decision": {
    "decision": null,
    "reviewer": null,
    "owner": null,
    "calendar_date": null
  },
  "disclosure": "Supporting records for a synthetic illustration; no institutional acceptance or live inspection is asserted."
}