Treating the risk: data and third parties
Treatment is where privacy is actually protected: the data you are allowed to use, the provenance you can show, the supplier terms you can enforce and the model behaviour you can test. The public record names treatment; it does not name the controls, so the controls below are the ones in force today.
The abstract says the guidance establishes mechanisms to treat the risks it identifies. It does not publish the mechanism. Any page that tells you the draft requires a particular technique is guessing.
What is not a guess is the control set that already applies. Data requirements, acquisition, quality, provenance and preparation are A.7 of ISO/IEC 42001. Suppliers, customers and responsibility allocation are A.10. Those controls are written for AI systems and they carry the evidence an auditor will ask for.
The privacy treatment that matters most is usually subtraction: do not use the field, do not keep the prompt, do not train on the customer record, do not let a supplier retain the output. Record the decision and the reason, because the next reviewer will ask why the data was needed at all.
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.