Question
Does a failure to respond to API requests during outage periods (planned outages and unplanned incidents) constitute a refusal to disclose CDR data that needs to be reported?
Answer
From a technical perspective, the reporting of a refusal to disclose means that the request is received and is valid but the data holder (for one of a variety of reasons) refuses to provide the requested data.
During a period of system instability or outage the first part of this technical definition may not be met. The initial request may not be received or may not be able to be assessed for validity. In these situations, a refusal to disclose does not need be recorded and does not need to be included in a data holder’s report.
This would, however, be recorded as a period of unavailability under the non-functional requirements in the Data Standards if the outage was unplanned. If the outage was planned and communicated with enough advance notice according to the standards then the calls would not need to recorded either as a period of unavailability or as a refusal to disclose.
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