AACF
Data & Information ยท DAT-07

Controlled access and sharing

AI systems and their users can reach only the data they need for the agreed purpose, and data is shared into and out of AI systems only under agreed rules.

Why it matters

AI systems are often given broad access to make them work quickly, and then surface data to users who would never have been allowed to see it directly. Applying least privilege and sharing rules to the AI system itself, not only to its users, keeps existing permissions meaningful.

Levels
0 AbsentConfirmed absent: the evidence shows nothing is in place. Not known is recorded as insufficient evidence, not 0.
1 InitialAI systems are given whatever access makes them work; sharing happens without agreed rules.
2 DevelopingAccess is restricted for some systems or data, but AI systems' own access is not reviewed and sharing rules are informal.
3 DefinedAccess to data by AI systems and users is limited to the agreed purpose and approved, sharing follows agreements, and live sensitive data in development is controlled.
4 ManagedAccess rights and sharing agreements for AI are reviewed on a set cycle, excess access is removed, and breaches of sharing rules are detected and acted on.
5 OptimisingAccess and sharing controls for AI are applied automatically from data classification and purpose, and are refined from review findings.
Level 3 criteria

Level 3 is met when every applicable criterion is met. Criteria marked with an overlay apply only to organisations with that characteristic (overlays).

  1. DAT-07.1 Access by each AI system and its users is limited to what the agreed purpose needs.
  2. DAT-07.2 Access by each AI system and its users is approved by the data owner.
  3. DAT-07.3 Sharing data with other systems or organisations follows documented agreements.
  4. DAT-07.4 A documented route exists for requesting access to data for AI work.
  5. DAT-07.5 Live personal or sensitive data is used in development, test or experimentation only with data owner approval.
  6. DAT-07.6 Live personal or sensitive data used in development, test or experimentation is minimised or protected.
Assessment questions
  • What data can this AI system reach, and could a user obtain through it something they could not see directly?
  • Who approved that access, and when was it last reviewed?
  • Where data is shared with another organisation or service for AI, what agreement covers it?
Evidence an assessor would expect
  • Access approvals and the latest access review for a sample of AI systems
  • Data sharing agreements covering AI use
How to reach Level 3
  1. For each AI system, define the data it and its users need for the agreed purpose and limit access to that, with data owner approval.
  2. Put sharing with other systems or organisations under documented agreements.
  3. Publish a route for requesting access to data for AI work.
  4. Require data owner approval before live personal or sensitive data is used in development, test or experimentation, and minimise or protect it when it is.

Common pitfalls

  • Giving an AI system broad service account access because it is easier to set up.
  • Copying live data into test environments without approval.

Starter artefacts

  • Access approval record per AI system
  • Data sharing agreement template
  • Data access request form
Ownership and sequence
Accountable
data owner
Contributors
security lead, delivery lead
Depends on
DAT-02
Roadmap step
2
Lifecycle
design, acquire_build, deploy, operate, retire
Cross-references
AI Cyber Security Code of Practice2.5 partial; 2.6 partial; 4.4 partial; 5.4 direct; 6.1 partial; 6.3 partial; 13.1 partial
Algorithmic Transparency Recording StandardTier 2 Development data specification direct; Tier 2 Operational data specification direct
JSP 936 Part 1para 168 partial
MITRE AI Maturity ModelP5.2 direct; P5.4 direct
NIST AI 600-1R4 partial
UK Data and AI Ethics FrameworkPrivacy 4 partial; Privacy 7 direct; Safety 3 partial; Safety 4 partial; SAT 1.7 direct; SAT 2.6 partial
UNESCO AI Maturity Framework3.4 partial; 6.3 direct

direct: this control at Level 3 meets the item. partial: it covers part of it.