A practical, copy-paste-ready policy and record structure for knowing which AI models your organization uses, who owns them, what evidence supports the vendor relationship, what approval the risk requires, and when to renew, remediate, suspend, replace, or offboard the system.
Generic reusable template · Replace bracketed fields · Route material decisions for required specialist review
Use this policy to establish the minimum record and decision path for AI models, model-enabled vendors, embedded AI features, and internally developed systems used by [Organization]. Customize the scope and approval authorities to your operating model and jurisdictions.
Define “material change” in local practice. At minimum, include a new model or version, a changed vendor or subprocessor, a new data category or jurisdiction, a new population or decision use, a material contract or DPA change, a performance or safety signal, or an incident. If the team is unsure whether a change is material, treat it as material until the accountable reviewer decides otherwise.
Create one record per system or materially different use case. Link related versions and vendors, but do not collapse distinct purposes into one row just to reduce administration.
| Field | Required entry | Evidence or note |
|---|---|---|
| System ID | [AI-###] | Stable identifier used in tickets, contracts, and monitoring. |
| Business owner | [Name / role / business unit] | Accountable for purpose, outcomes, budget, and lifecycle decision. |
| Technical owner | [Name / role / team] | Accountable for integration, access, configuration, and change control. |
| Vendor / model / version | [Vendor] · [Model] · [Version or release date] | Attach model card, release notes, contract terms, or internal build record. |
| Use case | [What the system does and where it is used] | State whether it informs, recommends, generates, ranks, or decides. |
| Data categories | [Public / internal / confidential / personal / sensitive] | List inputs, outputs, retention, training use, and access restrictions. |
| Jurisdictions | [Countries / states / regulated markets] | Include where people, data, customers, and decisions are located. |
| Risk tier | [Low / moderate / high / prohibited] | Record rationale and the approval path completed. |
| Contract / DPA status | [Executed / pending / not applicable] | Link contract, DPA, subprocessors, security addendum, and renewal date. |
| Approval date | [YYYY-MM-DD] | Record approvers, conditions, exceptions, and expiry if any. |
| Review date | [YYYY-MM-DD] | Next scheduled review; bring forward on a material change. |
| Monitoring owner | [Name / role] | Owns metric cadence, issue log, escalation, and evidence retention. |
| Lifecycle decision | [Pilot / approved / renew / remediate / suspend / replace / offboard] | Record decision date, rationale, conditions, and decision maker. |
Recommended attachments: data-flow diagram, access list, model or feature documentation, testing results, incident history, vendor evidence, contract and DPA, approval record, monitoring snapshots, and the latest renewal or offboarding decision. If an item does not apply, write [N/A — rationale]; do not leave material fields blank.
The business owner owns why the system exists; the technical owner owns how it operates; reviewers confirm whether the proposed use is acceptable; and the monitoring owner makes sure approval remains true over time.
| Role | Before adoption | During use | At review or exit |
|---|---|---|---|
| Business owner | Defines purpose, population, benefit, and success criteria. | Confirms use stays within approved purpose and budget. | Recommends renew, remediate, suspend, replace, or offboard. |
| Technical owner | Documents architecture, access, data flow, and safeguards. | Controls changes, permissions, integrations, and rollback. | Exports records, removes access, and confirms deletion or migration. |
| Risk / compliance reviewer | Confirms risk tier, required evidence, and conditions. | Tracks exceptions, incidents, and regulatory or policy triggers. | Confirms residual risk and whether conditions remain satisfied. |
| Security / privacy / legal | Reviews as required by data, contract, threat, jurisdiction, and use case. | Advises on incidents, material changes, and control gaps. | Confirms obligations for retention, notice, deletion, and transition. |
| Monitoring owner | Defines metrics, thresholds, cadence, and evidence location. | Publishes snapshots and escalates threshold breaches. | Brings evidence to the renewal or offboarding decision. |
For small teams, one person may hold multiple roles, but do not erase the distinct decisions. Record the role performed, the person approving, and any conflict or independence safeguard required by [Organization].
A vendor questionnaire is not a substitute for diligence. Send the questions below, request source materials, note limitations, and avoid converting a marketing claim into an approved control without corroboration.
| Evidence checklist | Status | Evidence reference / gap |
|---|---|---|
| Contract, DPA, subprocessors, and data-use terms | [Attached / pending / gap] | [Link or explain limitation] |
| Security report, certification, or completed review | [Attached / pending / gap] | [SOC 2 / ISO / questionnaire / other] |
| Model documentation, release notes, and service-change notice | [Attached / pending / gap] | [Version and date] |
| Testing, performance, safety, privacy, and bias evidence | [Attached / pending / gap] | [Test scope, population, and limitations] |
| Retention, deletion, export, and transition evidence | [Attached / pending / gap] | [Terms, procedure, or support ticket] |
| Incident history and notification commitments | [Attached / pending / gap] | [Timeframes and escalation contact] |
Set local thresholds with legal and compliance input. The example below is a governance starting point, not a universal risk taxonomy. A higher tier always overrides a lighter path when facts are uncertain.
| Risk tier | Typical characteristics | Minimum approval and conditions |
|---|---|---|
| Low | Internal productivity support; no sensitive inputs; no customer or employee decision impact; human checks output. | Business owner + technical owner; inventory record; basic vendor and data-use review; monitoring owner assigned. |
| Moderate | Confidential or personal data; external-facing content; material workflow influence; meaningful vendor dependency. | Business + technical owner; security/privacy or legal review as applicable; documented testing; contract/DPA status; time-bound approval and periodic monitoring. |
| High | Consequential recommendations or decisions; sensitive populations; regulated activity; material rights, access, safety, or financial impact. | Formal risk assessment; documented legal, privacy, security, compliance, and executive or committee review as applicable; human oversight; launch conditions; enhanced monitoring and incident plan. |
| Prohibited / no-go | Use violates law, contract, policy, vendor terms, data restrictions, or approved purpose; evidence is materially missing; safeguards cannot control residual risk. | Do not adopt or continue. Escalate to [role], document the rationale, and identify a safer alternative or remediation plan. |
Monitoring should answer whether the system still operates within the approved purpose, data boundary, performance range, vendor commitment, and risk tolerance. Keep snapshots and issue records where reviewers can retrieve them.
| Signal | Example metric or check | Cadence / owner | Escalation trigger |
|---|---|---|---|
| Usage and scope | Approved users, use cases, data categories, jurisdictions, access exceptions | [Monthly / quarterly] · [Owner] | Use outside approved purpose or population. |
| Quality and reliability | Accuracy, completion, rejection, latency, outage, fallback, or human override rate | [Weekly / monthly] · [Owner] | Metric crosses [threshold] or trend worsens for [period]. |
| Safety, privacy, and bias | Incidents, complaints, harmful output, privacy events, disparate outcomes, red-team findings | [Continuous / quarterly] · [Owner] | Any material incident or threshold breach. |
| Vendor and contract | Version change, subprocessor change, DPA status, SLA, security notice, data-use change | [At notice / quarterly] · [Owner] | Material vendor or contract change without re-review. |
| Inventory integrity | Required fields complete, review date current, evidence links live, exceptions closed | [Monthly / quarterly] · [Owner] | Record is stale, owner missing, or evidence cannot be produced. |
Change triggers: new model or version, vendor or subprocessor change, data or retention change, new jurisdiction, new decision population, changed automation level, material contract or DPA change, performance drift, security or privacy event, credible complaint, regulatory change, or an unresolved control exception.
Complete this record before a contract renews, a model version becomes unsupported, a control gap remains open, or the business no longer needs the system. “Renew” is one option, not the default.
| Decision | Use when | Required record and action |
|---|---|---|
| Renew | Purpose, evidence, controls, performance, and vendor terms remain acceptable. | New approval date, review date, contract status, monitoring evidence, and any conditions. |
| Remediate | Gap is controllable and the owner can close it within an approved time window. | Gap, risk owner, due date, interim control, and escalation if overdue. |
| Suspend | Continued use creates unacceptable uncertainty or a threshold, incident, or contract breach. | Disable or restrict access, notify users, preserve evidence, and define restart criteria. |
| Replace | Another system better meets the purpose, risk tolerance, data boundary, or vendor requirements. | Compare options, approve the replacement, migrate safely, and close the old record. |
| Data export | Records, prompts, outputs, configurations, or audit evidence must move to another system. | Export scope, format, owner, validation, transfer safeguards, and retention decision. |
| Deletion / offboard | Service is no longer needed, approved, supportable, or acceptable. | Revoke access, terminate integrations, request deletion, obtain confirmation, retain required evidence, and update inventory. |
Start with visibility and ownership, then add evidence and tiered review. Keep the first version usable; improve the controls as the inventory reveals where the real risk sits.
| Window | Priority | Checklist |
|---|---|---|
| Days 0–30 | Find and name | Appoint policy owner; publish definitions; collect known AI tools and embedded features; assign system IDs, business owners, technical owners, and monitoring owners; freeze unrecorded high-risk adoption. |
| Days 31–60 | Evidence and tier | Complete required metadata; classify data and jurisdictions; gather contracts, DPAs, security and model evidence; apply risk tiers; route moderate and high-risk records to required reviewers; record gaps and interim controls. |
| Days 61–90 | Operate and decide | Set metrics and thresholds; run the first monitoring review; test a change-trigger workflow; schedule review dates; complete one renewal or offboarding tabletop; report stale records, exceptions, and no-go decisions to [governance forum]. |
After day 90, make the inventory part of procurement, architecture review, security review, privacy review, change management, incident response, and annual planning. A record that is not connected to those workflows will drift.
The GovernIQ assessment maps the AI systems, data, owners, and policy gaps behind your current posture. The personalized Compliance Action Plan extends this template with company-specific approval language, vendor remediation priorities, and a 90-day implementation roadmap.
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