Operating, monitoring and telling people

ISO/IEC FDIS 27091ReadingPublic record onlyNot published

A privacy risk that appears in operation has to be seen, logged and communicated. The draft names evaluation and treatment across the lifecycle; the controls already in force ask for monitoring, event logs, incident communication and a route for an affected person to raise a concern.

Deployment is where the organization loses the ability to see what the model is doing. Prompts, retrieved records, outputs and human overrides all carry personal data, and most of them are kept by default in a tool nobody reviewed.

The controls that apply today are explicit. A.6.2.6 asks for operation and monitoring, A.6.2.8 for event logs that support accountability and investigation, A.8.4 for a plan to communicate incidents, and A.3.3 and A.8.3 for routes by which a concern can be raised from inside or outside.

Name the retention period for each store before the next deployment, not after the next incident. A log that keeps a prompt for two years is a privacy decision even when nobody called it one.

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.

Read the 38 control records Back to the public record