What was said
What this says
Current to 11 Oct 26Theo Gallagher proposed a closing session for the security review. Declan Furlong accepted Wednesday morning but demanded the written incident account before it, plus sub-processor detail and a retained exit plan document.
Ask: Declan agreed to a Wednesday morning session with one ICT risk colleague. He added three conditions: the written incident account first, sub-processors named for the July outage, and an exit plan he can retain.
Customer view: He will not close findings on verbal assurance and reminded Theo he expects the same promptness for any further incident.
Next: Theo cannot date the incident account alone, so he will confirm the delivery date in writing on Monday, before the session.
The thread
Updated 9 Oct 26Messages
- Theo Gallagher 31 Jul 2026 16:54Dear Declan, Thank you for your time on the call today. As agreed, I would like to fix a closing session for the security review so we can go through the open findings together and agree what evidence you still need. As I see the open findings and their owners: 1. Incident history and notification times for the July outage: a written account with a timeline. Owner: me, with input from the platform team. 2. Exit plan: the steps and the data return format. Owner: me. 3. Entries for your register of information: your team to confirm the fields you need, and I will map each one to a control reference. Could you let me know whether early next week suits you, Tuesday or Wednesday morning? Please also tell me who from your ICT risk team should join, so I can bring the right people from our side. Thanks, Theo
- Declan Furlong 31 Jul 2026 17:22Theo, Thank you. Your list matches mine, with one addition. 1. Wednesday morning is acceptable. One colleague from ICT risk will join me. 2. Under DORA we need the written incident account before the session, not at it. Please provide a dated commitment for when it will reach me. 3. For the register of information, please also state which of your sub-processors, if any, were involved in the July outage. I will not be able to close that finding on a verbal assurance. 4. Please confirm the exit plan will be a document I can retain, not a walkthrough. I would also remind you that I was told of the outage by your team on the day, and I expect the same promptness for any further incident. Regards, Declan Furlong, CISO
- Theo Gallagher 31 Jul 2026 17:37Declan, Understood, and thank you for being so clear. Taking your points in order: 1. Wednesday morning is booked from my side. I will send the invitation shortly. 2. The written incident account is something I cannot date on my own, as it depends on the platform team. I have asked them for a date this evening. Here is the dated commitment I can give you now: I will confirm the delivery date to you in writing on Monday, and it will be before the session. 3. Sub-processors: I will answer that in the incident account, with evidence attached, so you are not relying on my word. 4. The exit plan will be a retained document, sent with the incident account. On your last point, noted. I will make sure it is recorded as an open item. Thanks, Theo