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CHQ Position v2025.12

Position Type: Structural Governance Condition
Position Effective: December 2025

Disclosure Authority Without Evidentiary Custody

A standing governance position

This document records a binding judgment regarding breach disclosure authority under contemporary regulatory conditions.

It is written to preserve judgment continuity across board review, audit scrutiny, and regulatory dialogue.

This Position remains in effect until superseded by a future CHQ Position.

Position Statement

CybersecurityHQ adopts the position that breach disclosure obligations increasingly apply to organizations that do not possess forensic custody of incident evidence.

This condition produces a persistent separation between regulatory accountability and evidentiary authority. It exists independently of control maturity, vendor selection, contractual assurances, or security program sophistication. Disclosure judgment is therefore constrained regardless of technical posture.

This Position asserts that accountability for disclosure is now exercised under conditions where regulatory obligation precedes evidentiary control, and that this misalignment is not correctable within the disclosure window itself.

Decision Continuity Access required