Communicate legal holds or exceptions I I A/R Require vendor notification procedures. Is this correct

1. What your line likely tries to say — and why it falls short

Your phrase mixes three separate obligations — communicating legal holds to custodians, marking exceptions or acknowledgements (A/R), and requiring vendor notification procedures — but it reads like checklist tokens rather than actionable policy. Industry guidance emphasizes: issue a formal written hold to custodians with acknowledgement and tracking (Everlaw, Relativity, TechTarget) ^{[4] [5] [6]}, and separately document vendor oversight and notification requirements where third parties hold relevant records (HHS and Regulation S‑P) ^{[2] [3]}. Your item needs to be expanded into discrete, testable steps citing responsible roles and timelines ^{[1] [7]}.

2. Custodian communications: required, trackable, and often automated

Legal and ediscovery tooling providers and best‑practice guides treat custodian notification as a formal, auditable process: create a template notice, send by email (and sometimes alternate channels), collect acknowledgements, send periodic reminders, and log receipt and compliance evidence (Relativity; Everlaw; TechTarget; Mitratech) ^{[5] [4] [6] [8]}. Microsoft’s Purview explains the communications workflow for custodian notifications and tracking in eDiscovery (Premium) ^[1]. Note: Microsoft retired some classic communications features but still supports communications workflows in newer tooling ^{[9] [1]}.

3. Exceptions and acknowledgements (the “A/R” in your note) need definition

Your “A/R” seems to signal acknowledgement/receipt, or accept/reject flags; sources make clear the essential element is documented acknowledgement and follow‑up. Templates should require custodians to confirm receipt and understanding, and legal teams must escalate unacknowledged notices with reminders and managerial alerts (TechTarget; Relativity; Thomson Reuters) ^{[6] [5] [10]}. If by “exceptions” you mean permitted deviations from preservation, those must be documented, approved by counsel, and recorded in the hold’s audit trail — best practice described across litigation‑hold lifecycle guides ^{[7] [10]}.

4. Vendor/third‑party data: you cannot assume custody; require procedures

When relevant data is held by vendors, contractors, or service providers, federal and agency policy expects coordination: HHS requires conferring with contracting officers and OGC before issuing holds to covered recipients and mandates notification procedures for when staff or covered recipients learn of potential litigation ^[2]. Financial institutions subject to SEC/Regulation S‑P amendments must contractually obligate service providers to notify the institution of security incidents (within defined timeframes) and to take appropriate protections — an analogous oversight posture for preservation duties ^[3]. Your checklist must therefore spell out contractual notification triggers, timelines, and vendor oversight steps ^{[2] [3]}.

5. Recommended rewrite — clear, testable policy language

Turn your tokens into three discrete directives: (a) Issue written legal‑hold notices to identified custodians and require documented acknowledgements; use automated communications and reminder/escalation chains and preserve the audit trail ^{[4] [5] [1] [6]}; (b) Define what “exceptions” mean, require counsel approval for any deviation, and record all exceptions in the hold record ^{[7] [10]}; (c) For vendors/contractors, require contractual notification of preservation and of security incidents, designate vendor points of contact, and coordinate issuance of any hold to covered recipients via contracting officers/legal counsel ^{[2] [3]}.

6. Conflicting practices and limitations in current sources

Vendor notification expectations vary by sector: HHS posits a consultative process before notifying contractors ^[2], while Regulation S‑P imposes strict contractual incident‑notification obligations for covered financial institutions ^[3]. Tool vendors focus on custodian communications and tracking but do not standardize vendor contractual terms ^{[4] [5] [1]}. Available sources do not mention a single universal template or a one‑size‑fits‑all SLA for vendor notification timing across all industries — you must map policy to sectoral rules ^{[3] [2]}.

7. Bottom line and next steps for you

Refine the entry into explicit policy statements with responsibilities, timelines, and audit requirements: require written custodian notices with acknowledgements and escalation; define exceptions and approval flow; and require vendor notification and contractual oversight tailored to your regulatory regime (HHS or Regulation S‑P as applicable) ^{[2] [3] [7]}. For operational detail, adopt an eDiscovery tool that logs communications and acknowledgements and pair it with legal‑approved vendor clauses and incident notification terms ^{[1] [4] [5]}.