Scope, role and who answers

ISO/IEC FDIS 27091Public scopePublic record onlyNot published

The draft applies to every organization that develops or uses AI systems, and it asks about privacy risk rather than security risk alone. Who answers depends on the role the organization plays in the personal data.

The ISO abstract reaches organizations of every size and type, naming public and private companies, government bodies and not-for-profit bodies among those that build AI systems or use them. It does not limit itself to developers, and it does not limit itself to one sector.

Privacy protection turns on a question the abstract does not answer for you: whether the organization decides why personal data is processed, or processes it for someone else. A developer that trains a model on customer data can be either. A user that drops personal data into a bought system can be either. The role has to be settled before the obligation is chosen.

This site reads the role question from ISO/IEC 27701, named on the reference page, and the management questions from the ISO/IEC 42001:2023 control record. Both are in force today. The draft adds a privacy lens over the same lifecycle; it does not create a new certification.

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