Ardcarne Life Assurance / BG-Demo – Security Review
Callcompleted
Ardcarne Life Assurance · 2 Jun 2026 09:15
Session two covered the exit plan annex and data return with the CISO and the Head of Procurement and Outsourcing. The annex is a draft, assistance period length and log retention are open, and procurement will not skip a policy step to hit 30 Jun 2026.
What was said
What this says
As at Fri 9 Oct 2026Session two covered the exit plan annex and data return with the CISO and the Head of Procurement and Outsourcing. The annex is a draft, assistance period length and log retention are open, and procurement will not skip a policy step to hit 30 Jun 2026.
What happened: Theo Gallagher took Declan Furlong and Aoife Kinsella, new on this call, through the draft exit plan annex. Declan opened with four open findings and Theo added a fifth on what BG-Demo holds outside the Snowflake account.
Customer view: Declan liked that verification of access removal sits with Ardcarne, but wants a signed deletion confirmation for items outside the account. Aoife asked for insolvency and change of control triggers and an annual documented review.
Commercial: Aoife said she cannot agree terms on a call and will not discuss price until the exit plan is settled. The assistance period length sits with procurement and BG-Demo's commercial side.
Watch: Both said the 30 Jun 2026 date moves if the exit plan is not settled.
Themes
As at Fri 9 Oct 2026Theme
Exit plan and data return
Importance
neutral
Sentiment
mixed
Voice
decision-maker
Who was there
BG-Demo
CRMmade from
Them
CRMmade from
Follow-up
Next steps
As at Fri 9 Oct 2026- Theo Gallagher to send the written follow-up with the amended annex, open questions, owners and dates.
- Theo to confirm in writing the signatory for deletion confirmation, by role.
- Aoife Kinsella to take the trigger wording to Legal once received.
Risks
As at Fri 9 Oct 2026- The exit plan annex is a draft and the assistance period length is unsettled.
- Log retention and an exit rehearsal depend on the platform team and are unconfirmed.
- Procurement and Legal may move the 30 Jun 2026 date if the exit plan is not settled.
Opportunities
As at Fri 9 Oct 2026- Verification of access removal by Ardcarne's own query was well received.
- Settled exit terms would clear a step towards the order form.
Transcript
Theo GallagherMorning, Declan. Morning, Aoife. Can you both hear me all right?
Declan FurlongGood morning, Theo. Yes, clear on my side.
Aoife KinsellaMorning. I can hear you, but I think I'm a touch quiet. Is that better?- Theo GallagherBetter, yes. Thanks. Apologies, I'm in a different room today, so if the echo is bad, say so and I'll move.
- Aoife KinsellaNo echo. It's a grim morning in Dublin, so I'm glad of the excuse to be indoors.
- Theo GallagherSame here, rain all the way in. Right. Shall I start with where we are? This is the second of the four sessions, and today is exit plan and data return.
- Declan FurlongPlease do. Though if I may, I would like to list the open findings first, so we are all working from the same register.
- Theo GallagherOf course. That's how I'd normally open as well, so go ahead.
- Declan FurlongThank you. Under DORA we need the following still open from the first session. One, the exit plan itself, in a form that can go into the register of information. Two, the mechanism and format of data return on termination. Three, the termination assistance period and what it covers. Four, evidence that access is removed and nothing is retained after exit. Those are the four I have against your name.
- Theo GallagherThat matches my list. I have the same four, and I'd add a fifth for my side: the written statement of what BG-Demo holds outside your Snowflake account, because that decides most of the answer to your second point.
- Declan FurlongAgreed. Please add it. I would rather the fifth were visible than discovered later.
- Aoife KinsellaBefore we go further, can I confirm which draft we are discussing? I have the exit plan annex that Theo sent after the first session, and a separate section in the draft order form. From an outsourcing perspective I want to be sure we are not mixing the two.
- Theo GallagherGood question. We're on the annex. It's a draft, not final, and the order form section simply points to it. Anything we agree today is a change request to the annex, not to the order form.
- Aoife KinsellaThank you. And for the minutes, I can't agree terms on a call. Everything today is subject to Legal.
- Theo GallagherUnderstood, and that's fine. I'm not looking for agreement today, I'm looking to get the wording right so Legal has something sensible to read.
- Theo GallagherSo let me explain the architecture in plain terms, because it shapes everything. The brain is built and run inside your Snowflake account. The tables, the indexes, the pages, the derived data, all of that sits in your account, under your keys and your roles. BG-Demo does not hold a copy of your data in our own estate.
- Declan FurlongWhich is the claim in the first session. What I need to understand is where that stops being true. What does BG-Demo hold that is outside the account?
- Theo GallagherRight, so three things. Support records, meaning tickets and any attachments you choose to send us. Deployment configuration, which is the definition of which connectors are on and how they map. And operational logs from the service. I'll be careful here: I can evidence the first two today. For the logs, I need to check exactly what is retained and for how long, and I'm not going to answer that from memory.
- Declan FurlongThat is the correct instinct. Please note it as an open point. Who confirms it on your side?
- Theo GallagherThe platform team. I'll ask them directly and put their answer in writing rather than relay it. I don't want to answer for them on a call.
- Declan FurlongNoted. Please provide a dated commitment for that answer.
- Theo GallagherYes. Give me a moment to look at my diary, I'd rather give you a date I can keep. Within a week of this call, so by the next session at the latest. I'll write it into the follow-up.
- Declan FurlongThank you. Continue.
- Theo GallagherSo on exit. I'll go through the annex in the order of the stages. Stage one is notice and scoping. Stage two is the assistance period, where we keep the service running read-only if you want it, and help you move whatever you need. Stage three is removal: we take out the objects we deployed and revoke every credential and role we were given. Stage four is the confirmation, in writing, with evidence.
- Aoife KinsellaLet me stop you at stage two. The exit plan needs to cover who decides when the assistance period starts. In the annex it says on notice of termination. Is that notice from us only, or also from BG-Demo?
- Theo GallagherEither side. If we terminate, or if the contract ends and isn't renewed, the same plan applies. I think the wording in the annex is ambiguous on that, so I'd suggest we say it explicitly.
- Aoife KinsellaPlease. And I would want it to say that the plan also applies if BG-Demo is subject to insolvency or a change of control, not only for convenience. Our outsourcing policy is explicit about that.
- Theo GallagherI'll draft that as a trigger list. I can't say the commercial side will love every trigger, but from a security and exit point of view I have no objection, and I'll mark it as a proposal.
- Aoife KinsellaThat is all I ask at this stage.
- Declan FurlongNow data return. In your annex you say the data stays in our account. Strictly, that means there is nothing to return. I would like that spelled out, because an examiner will not read it charitably. What exactly is returned, in what format, and what is the evidence that it is complete?
- Theo GallagherFair. Let me answer in numbered form, since it mirrors your questions. First, what is returned. The core data is already yours, in your tables. What we hand back is the things we built on top: the schema definitions, the mapping configuration, the page and dashboard definitions, and the documentation of how each connector was set up.
- Theo GallagherSecond, format. Tables stay as tables in Snowflake. Definitions and mappings go as plain text files in open formats, so nothing needs our software to read them. Third, completeness. We produce a manifest listing every object and file, and you can reconcile that against what is in your account. That's the control reference I'd point at, and we can evidence that on a test run.
- Declan FurlongA test run. Is that offered, or is it something you would consider?
- Theo GallagherI'd like to offer it, but I should be honest that I haven't confirmed it with the platform team. What I can say today is that the manifest exists in the product already. Whether we can run a full exit rehearsal in a sandbox before go-live, I need to ask.
- Declan FurlongThen it is an open question, not a commitment. I will record it that way.
- Theo GallagherYes, please do. That's accurate.
- Aoife KinsellaCan I come back to the assistance period? The annex has a placeholder for how long it runs. Not a number I would expect you to give me today, but what does it need to cover? From an outsourcing perspective I need to see that we are not left without the service while we move.
- Theo GallagherSo it needs to cover continued read access for your teams, support for the migration, and the removal and confirmation work at the end. On the length, I'm not going to put a figure on a call. It needs to be long enough for your own migration plan, and that is a conversation between your outsourcing team and our commercial side.
- Aoife KinsellaThat is acceptable. I will say that I will not discuss price on it until the exit plan is settled, so I would suggest we keep it as a plan question for now.
- Theo GallagherEntirely agree. I'll keep commercial matters out of the annex. My colleague Matteo handles the order form, and I'll make sure he knows the sequence.
- Aoife KinsellaThank you. I appreciate it.
- Declan FurlongFourth finding: evidence that access is removed. Walk me through that. Who removes what, and who verifies?
- Theo GallagherRight. Because we run inside your account, the roles and grants are yours. So the cleanest design is that your administrators remove our roles, with our guidance, and we provide a checklist. We never hold the only key. You then run a query that lists grants to our role names and confirm it returns nothing. That output is the evidence.
- Declan FurlongThat is better than a certificate from the supplier. I do like that the verification sits with us.
- Theo GallagherThat was the intention. A supplier saying it has deleted things is a weaker control than you being able to see it yourself.
- Declan FurlongAgreed. But for the items outside our account, the support records and logs, we do not have that visibility. There I need a deletion confirmation, with a date, and the scope.
- Theo GallagherYes. That's the fifth item I added. For those I'd propose a written deletion confirmation signed off by someone accountable at BG-Demo, with the scope listed. I can propose that wording, but again, who signs and the retention behind it is for the platform team and our security lead to confirm.
- Declan FurlongThen please confirm, in writing, the signatory by role.
- Theo GallagherWill do. By role, with a dated commitment.
- Aoife KinsellaSomething slightly different, Theo. The register of information needs the exit strategy to be tested periodically. Does the annex say anything about how often the exit plan is reviewed?
- Theo GallagherIt says it's reviewed at renewal, and I don't think that's enough for you. I'd suggest an annual review, and a review after any material change to the architecture or to a connector set. I'll put that in as a proposal.
- Aoife KinsellaAnnual is what our policy requires, yes. And the review should be documented and shared with us, not just done.
- Theo GallagherDocumented and shared. Noted.
- Declan FurlongOne more matter and then I think we may be near the end of the useful ground. If the contract is signed on the date your side has indicated, which is 30 Jun 2026, will these findings be closed by then?
- Theo GallagherI'd rather not promise that on a call. What I can say is that the ones in my control I'll answer in writing with evidence. The ones that depend on the platform team I'll flag with owners and dates. Whether that's enough to close each by 30 Jun 2026 is your call, not mine.
- Aoife KinsellaAnd I should say that I will not skip a policy step to hit a date. If the exit plan is not settled, the date moves. It has moved before.
- Theo GallagherUnderstood, and I think that's the right way round.
- Declan FurlongThen let me summarise what I will record. One, the exit plan annex is amended for triggers, to be sent by you. Two, data return is described as definitions, mappings and a manifest, with tables remaining in our account. Three, the assistance period length is open and sits with procurement and your commercial side. Four, verification of access removal is by our own query, and for items outside our account a signed deletion confirmation is required. Five, the rehearsal and the log retention are open pending your platform team. Is that fair?
- Theo GallagherThat's fair, and it's more tidily put than I had it. I'll mirror those five in the follow-up so you can paste them straight into your register.
- Aoife KinsellaThank you both. I will take the trigger wording to Legal once I have it.
- Theo GallagherThen I'll send the written follow-up with the amended annex and the open questions, owners and dates. Thanks both.
- Declan FurlongRegards. Until the next session.
- Aoife KinsellaGoodbye, both. Kind regards.
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