Data owner
Accountable for the data an AI use depends on.
- Often held by
- a chief data officer, head of data or the information asset owner for the data concerned
- Accountable for
- 8 controls
- Contributes to
- 21 controls
- Relies on
- Delivery lead (6), AI governance lead (5), Business owner (3), Risk lead (3), Executive sponsor (1), Security lead (1)
- Supports
- Delivery lead (9), Business owner (5), AI governance lead (3), Risk lead (2), Security lead (2)
Accountable for
This role answers for each of these controls reaching the level the organisation has set, and holds the evidence.
Data strategy supports AI
The organisation's data strategy states what its planned uses of AI need from data and sets out how those needs will be met.
With: Executive sponsor, AI governance lead, Delivery lead.
Evidence an assessor would expect
- The approved data strategy, with the sections covering AI needs
- A data action plan or roadmap linked to the AI roadmap, with owners and progress
- The approved data architecture
Data ownership and stewardship
Every data set used by AI has a named accountable owner and day-to-day stewards who understand the data and look after it.
With: AI governance lead, Business owner.
Evidence an assessor would expect
- A register of data owners and stewards covering data used by AI
- Role descriptions or terms of reference setting out owner and steward responsibilities
- Examples of owners approving or declining a use of their data
Data quality fit for purpose
The quality of data used by each AI system is assessed against what that use needs, and shortfalls are fixed or their effects managed before and during live use.
With: Delivery lead, Business owner.
Evidence an assessor would expect
- Data quality requirements for a sample of uses of AI
- Data quality assessment results and the remediation actions that followed
Finding and understanding data
Data available for AI is catalogued and described well enough that people can find it, understand what it means and its limits, and use it correctly.
With: Delivery lead, AI governance lead.
Evidence an assessor would expect
- The data catalogue, with sample entries for data used by AI
- The process for adding and updating catalogue entries
Lawful and fair use of data
Before data is used in an AI system, its use is confirmed as lawful, consistent with the purpose for which it was collected, and fair to the people it describes.
With: Risk lead, Business owner, AI governance lead.
Evidence an assessor would expect
- Recorded decision on privacy enhancing techniques for each training or tuning data set that holds personal data
- Records of lawful basis, purpose compatibility and fairness for a sample of uses of AI
- Data protection advice or sign-off on those uses
- Notices telling people how their data and inputs are used, accessed and stored
Records management for AI
Retention and records rules cover what AI systems take in and produce, including prompts, outputs and the decisions they supported, and are applied in practice.
With: Risk lead, Delivery lead, AI governance lead.
Evidence an assessor would expect
- Retention schedule or records policy entries covering AI inputs, outputs and decisions
- Configuration records showing retention settings in AI tools
- Results of a retrieval or deletion check
- Retention settings for AI system logs
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.
With: Security lead, Delivery lead.
Evidence an assessor would expect
- Access approvals and the latest access review for a sample of AI systems
- Data sharing agreements covering AI use
Provenance of training and test data
For data used to train, tune or test AI, the organisation knows and records where it came from, what rights it holds over it, and any limits on its use.
With: Delivery lead, Risk lead.
Evidence an assessor would expect
- Provenance records for training and test data sets
- Licence or rights documentation for externally sourced data
- Links between data sets and the models or versions that used them
- Preparation, labelling and synthetic data records
Contributes to
Another role is accountable; this one does part of the work or supplies what it needs.
Oversight forum
A cross-functional forum oversees AI use, risk and performance, with terms of reference, the right membership and a clear link to the organisation's main governance.
Accountable: AI governance lead.
Named owners for each use of AI
Every use of AI has named owners for the business outcome, the data, the technology and its assurance, recorded where others can find them.
Accountable: AI governance lead.
Integration with existing governance
AI governance works through the organisation's existing risk, information, data protection, security and procurement governance rather than alongside it.
Accountable: AI governance lead.
Impact assessment before deployment
Before a use of AI goes live, its likely effects on people and groups (including equality, privacy, rights and safety) and on society and the environment are assessed to a depth that matches its risk, and the findings are acted on.
Accountable: Business owner.
Legal and regulatory obligations
The organisation keeps a current view of the laws, regulations and standards that apply to its use of AI, with an owner for each obligation and a way of checking it is met.
Accountable: Risk lead.
Fairness and bias management
Unfair bias is identified, tested for and reduced at each stage of a use of AI, from design through to live operation.
Accountable: Business owner.
Explanation and challenge for affected people
People affected by decisions that AI supports can find out that AI was involved, get an explanation they can understand, and challenge the outcome through a route that can change it.
Accountable: Business owner.
Risk of AI from suppliers
Before AI in a bought product or service is used, and when it changes, the organisation assesses what it does, how it uses data, how the supplier changes the model, and what assurance the supplier offers.
Accountable: Risk lead.
Safe experimentation
Staff can try AI quickly within defined guardrails covering approved environments, data limits, time limits and exit criteria.
Accountable: Delivery lead.
Retiring uses of AI
Uses of AI that no longer earn their place are withdrawn through a planned process that covers users, dependent processes and disposal or retention of models and data.
Accountable: Business owner.
AI-aware procurement and contracts
Contracts for AI products and services set clear terms on data rights, intellectual property, notice of model changes, transparency and exit.
Accountable: Delivery lead.
Supplier performance and exit
AI suppliers are managed against agreed performance measures, and each critical AI service has a tested route to exit or replace the supplier.
Accountable: Delivery lead.
Approved AI tools and platforms
The organisation keeps a current list of approved AI tools and platforms, each with clear conditions of use, and staff know where to find it.
Accountable: Delivery lead.
Reference architecture for AI
Agreed architecture patterns set out how AI components fit into the technology estate, and new uses of AI follow them or record why not.
Accountable: Delivery lead.
Hosting and data location
Requirements for where AI is hosted and where its data is processed and stored are defined, and each use of AI is checked against them before and during live use.
Accountable: Delivery lead.
Integration with existing systems
AI is connected to core systems through supported, documented interfaces that the organisation can maintain, change and switch off.
Accountable: Delivery lead.
Testing and evaluation before release
Before release, each AI system is tested for accuracy, robustness and behaviour against acceptance criteria agreed in advance, and released only if it meets them.
Accountable: Delivery lead.
Preventing information leakage through AI
Sensitive information is protected from exposure through AI tools, prompts, training and outputs, with rules staff understand and technical measures that enforce them.
Accountable: Security lead.
Security testing of AI before release
Before release, each AI system is security tested against the threats in its threat model by suitably skilled testers, including checks that it does not disclose personal or sensitive information.
Accountable: Security lead.
Performance measures and baselines
Each use of AI has agreed performance measures and a recorded baseline of current performance before it goes live.
Accountable: Business owner.
Monitoring live AI
Live AI is monitored against its measures for accuracy, drift, misuse and unexpected behaviour, with thresholds that trigger action.
Accountable: Delivery lead.