Evaluating the consequences
The draft asks for the consequences of privacy risk to be weighed before and during use. The ISO/IEC 42001 impact assessment controls are the closest thing already in force, and they ask for the same evidence: who is affected, how, and what was decided.
The abstract names two mechanisms, evaluation and treatment. Evaluation is an assessment of consequences, not a checklist of data fields. The questions are who is affected, what happens to them, how likely it is and what would make it worse.
In ISO/IEC 42001:2023 the impact assessment controls sit at A.5. They ask for a process, for documentation, for an assessment of individuals or groups and for a separate look at societal impact. Read beside a privacy impact assessment, they cover much of the ground the draft describes, and they are auditable today.
The gap most organizations have is not a missing template. It is that the assessment stops at the model and never reaches the person: the applicant screened out, the tenant flagged, the patient whose record was in the training set. Write the consequence in the person's terms, then name the control that answers it.
What an auditor or a privacy reviewer is likely to ask for
- Scope The AI systems in use and the personal data each one touches, with the role the organization plays in that data.
- Assessment The impact assessment for each system, the groups considered, the harms named and the decision taken.
- Control The data and provenance record, the supplier terms, the retention setting and the test that the control works.
- Review The monitoring thresholds, the log retention, the incident route and the date of the last review.
These are the records this site expects a reader to hold for the area. They are our reading of the public record and the current controls, not 27091 draft text.
Where it commonly fails today
- The AI systems are not listed, so the assessment covers the model and misses the personal data around it.
- The assessment stops at accuracy and never reaches the person the output decides about.
- The data provenance is a folder of files with no record of where each dataset came from or on what basis.
- A supplier changes the model or the retention period and the assessment is not repeated.
- The logs hold prompts and outputs far longer than anyone decided they should.
What to do now, while it is still a draft
Do not rebuild the system around a draft. Do the work that will be right under either instrument: list the systems and the data, settle the role, run the impact assessment, record the provenance, fix the supplier terms, set the retention and test the incident route. If the published guidance differs, the process survives the wording change.
Source for this public record page: the ISO page 56582 and its stage feed, with the current control set where a requirement is stated. The draft text is not public and is not reproduced. Every source.