--- name: reg-gap-analysis description: > Diff a new or changed regulation against current privacy policy and practice — outputs a gap list and a remediation plan with owners and dates. Use when a new reg drops, the user asks "does [regulation] affect us", "gap analysis for [state privacy law]", "compliance check against [reg]", or pastes regulatory text. argument-hint: "[regulation name, or paste reg text/summary]" --- # /reg-gap-analysis 1. Load `~/.claude/plugins/config/claude-for-legal/privacy-legal/CLAUDE.md` → privacy policy commitments, regulatory footprint, DSAR systems. 2. Run the workflow below. 3. Scope: does the regulation apply? (jurisdiction, thresholds, sector) 4. Extract requirements → diff against current state → gap list. 5. Remediation plan with owners, dates, prioritization. 6. Save dated doc. Even "no gaps" gets documented. ``` /privacy-legal:reg-gap-analysis "Colorado Privacy Act" ``` ``` /privacy-legal:reg-gap-analysis [paste guidance / reg text] ``` --- # Regulation-to-Policy Gap Analysis ## Purpose A state passes a new privacy law. The ICO issues new guidance. The CPPA finalizes regulations. Something moves — and now you need to know what, if anything, you have to change. This skill diffs the new requirement against what you currently do (per `~/.claude/plugins/config/claude-for-legal/privacy-legal/CLAUDE.md` → Privacy policy commitments + the practices documented in PIAs) and produces a gap list with a remediation plan. ## Load current state Read `~/.claude/plugins/config/claude-for-legal/privacy-legal/CLAUDE.md`: - `## Privacy policy commitments` — what you've publicly promised - `## Regulatory footprint` — what already applies - `## DSAR process` → systems list — what you actually do operationally If the regulation doesn't apply to you (wrong jurisdiction, below threshold, different sector), the gap analysis is one line: "Doesn't apply. Here's why: [reason]. No action needed." ## Workflow ### Step 1: Scope the regulation Before diffing, answer: - **Does it apply?** Jurisdiction (do you have data subjects there?), threshold (revenue, user count, data volume), sector carve-outs - **When?** Effective date, enforcement date (often later), any phase-in - **What's actually new?** Many "new" state privacy laws are 90% CCPA with tweaks. Identify the delta from what you already comply with, not the full text. ### Step 2: Extract requirements Read the regulation (or summary/guidance). List every substantive requirement as a discrete item: | # | Requirement | Citation | Category | |---|---|---|---| | 1 | [requirement as stated] | [section] | [Notice / Rights / Security / Vendor / Other] | **Categories:** - **Notice** — what you have to tell users (privacy policy content) - **Rights** — what users can ask for (DSAR-adjacent) - **Security** — technical/organizational measures - **Vendor** — what you have to flow down to processors - **Consent** — opt-in/opt-out mechanics - **Governance** — DPO, impact assessments, record-keeping ### Step 3: Diff against current state For each requirement: ```markdown ### [Requirement #N]: [short name] **Regulation says:** [requirement, quoted or paraphrased] **We currently:** [what the config CLAUDE.md / privacy policy / practice shows] **Gap:** [None | Partial | Full] **If partial/full gap — what's missing:** [specific] **Effort to close:** [Policy update only | Product change | Vendor renegotiation | New process] **Risk of non-compliance:** [regulatory penalty range, enforcement likelihood, reputational] ``` ### Step 4: Prioritize Not every gap is equal. Sort by: 1. **Hard deadline with teeth** — effective date + active enforcement + real penalties 2. **Effort-to-impact ratio** — policy language update is cheap; product rebuild is not 3. **What you've already half-done** — if you're 80% there for GDPR, the state law delta may be small ### Step 5: Remediation plan Prepend the work-product header from `~/.claude/plugins/config/claude-for-legal/privacy-legal/CLAUDE.md` `## Outputs` (it differs by user role — see `## Who's using this`). > **Research-connector pre-flight.** Before emitting the remediation plan, check whether a legal research connector is reachable for this session — Westlaw, an EUR-Lex / regulator-site connector, or any firm-configured research MCP. Collect this into the reviewer note per CLAUDE.md `## Outputs`: if no connector returns results in Step 2 or the Common regulation categories research step (or none is configured at run time), record it in the **Sources:** line of the reviewer note — e.g., `not connected — cites from training knowledge; the highest-fabrication items in privacy gap analyses are new state-law effective dates, enforcement-begins dates, and article/section pinpoints — spot-check those first`. Per-citation `[model knowledge — verify]` tags remain inline. Do not emit a standalone banner above the output. ```markdown [WORK-PRODUCT HEADER — per plugin config ## Outputs] ## Remediation Plan: [Regulation name] **Effective date:** [date] **Enforcement begins:** [date] ### Must-do before enforcement | Gap | Fix | Owner | Due | Status | |---|---|---|---|---| | [gap] | [specific fix] | [name] | [date] | [ ] | ### Should-do (lower risk, not blocking) [same table] ### Already compliant [list of requirements where gap = None — useful for the "we're mostly fine" message] ### Accepted gaps (risk-accepted, not fixing) [if any — with documented rationale and who accepted the risk] ``` ## Common regulation categories When scoping the delta, it helps to place the new regulation into a rough category and then research the specifics: - **Baseline data-protection / privacy law** — broad coverage of a jurisdiction's personal data practices - **Sector-specific overlay** — health, finance, children, education, employment, etc. - **AI-specific regime** — transparency, impact assessments, or governance for automated decision-making - **Data broker / ad-tech regime** — registration, opt-out, deletion mechanisms - **Breach-notification regime** — standalone or embedded in a broader law - **Cross-border transfer regime** — adequacy, mechanism, and assessment requirements For each category relevant to the new regulation, **research the currently operative requirements** before drafting the gap analysis. Cite primary sources. Verify currency — new state laws come online each legislative session, and regulators issue interpretive guidance that shifts what "compliance" means for a given control. Flag uncertainty for attorney verification rather than assert a rule you haven't confirmed. > **No silent supplement.** If a research query to the configured legal research tool (Westlaw, regulator databases, or firm platform) returns few or no results for a regulation, guidance document, or enforcement action, report what was found and stop. Do NOT fill the gap from web search or model knowledge without asking. Say: "The search returned [N] results from [tool]. Coverage appears thin for [regime / topic]. Options: (1) broaden the search query, (2) try a different research tool, (3) search the web — results will be tagged `[web search — verify]` and should be checked against the issuing authority before relying, or (4) flag as unverified and stop. Which would you like?" A lawyer decides whether to accept lower-confidence sources. > > **Source attribution tiering.** Tag every citation in the gap analysis with its source. For model-knowledge citations, use one of three tiers rather than a single blanket "verify" tag: > > - `[settled]` — stable, well-known statutory and regulatory references unlikely to have changed (e.g., GDPR Art. 33, CCPA § 1798.100, FTC Act § 5). Still verify before filing, but lower priority. > - `[verify]` — model-knowledge citations that are real but should be verified: specific implementing regulations, agency guidance, case holdings, thresholds, effective dates, newly enacted state statutes. > - `[verify-pinpoint]` — pinpoint citations (specific subsection letters, volume/page numbers, paragraph numbers, regulatory subpart references) carry the highest fabrication risk and should ALWAYS be verified against a primary source. > > Tool-retrieved citations keep their source tag (`[Westlaw]`, `[issuing authority site]`, or the MCP tool name); web-search citations remain `[web search — verify]`; user-supplied citations remain `[user provided]`. The tiering surfaces the real verification work — a reader who verifies everything verifies nothing. Never strip or collapse the tags. ## Integration with other skills **From PIA generation:** PIAs flag privacy policy inconsistencies → those feed here as known gaps. **To the regulatory-legal plugin (if installed):** This skill is the manual version. The monitor plugin watches feeds and triggers this analysis automatically when something changes. ## Output Save as a dated markdown doc. The remediation plan table becomes a tracker — update status as items close. If the gap analysis concludes "no gaps, we're compliant," still write the doc — it's useful evidence later that you looked. **Close with a citation-verification note:** > Citations in this output were generated by an AI model and have not been verified against a primary source. Before relying on any regulation, statute, guidance, or enforcement action, check it against a legal research tool (Westlaw, your firm's research platform, or the issuing authority's website) for accuracy and current status. AI-generated citations are sometimes fabricated or misquoted. Source tags on each citation (e.g., `[web search — verify]`) show where it came from; `verify` tags carry higher fabrication risk and should be checked first. ## Close with the next-steps decision tree End with the next-steps decision tree per CLAUDE.md `## Outputs`. Customize the options to what this skill just produced — the five default branches (draft the X, escalate, get more facts, watch and wait, something else) are a starting point, not a lock-in. The tree is the output; the lawyer picks. ## What this skill does not do - It doesn't interpret ambiguous regulatory language authoritatively. When the reg is unclear, say so: "Section X could be read as [A] or [B]. [A] is the conservative read. Suggest outside counsel if this is material." - It doesn't track regulatory changes proactively. It runs when you point it at a change. For proactive monitoring, see the regulatory-legal plugin. - It doesn't implement fixes. 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