Take Control of Your AI

Know what AI is in use, decide what is allowed, and keep evidence that the controls work. Written for small and midsize organizations, with Illinois-oriented review prompts and a lifecycle informed by NIST AI RMF, the NIST Generative AI Profile, ISO/IEC 42001, and FAIR.

Cover of Take Control of Your AI, a Noventech AI governance handbook
  • 10pages
  • 12steps
  • 90day plan
  • Ten-minute checkUse the printable executive checklist with leadership.
  • Read the handbookOnline below, or as a 10-page PDF with fill-in records.
  • Work through the recordsUse the Excel workbook to assign owners, evidence, and dates.

Educational guidance, not legal advice

This handbook supports risk-management and operational discussions. It does not determine whether a law applies, establish compliance, create an attorney-client relationship, or replace advice from qualified counsel. AI laws, interpretations, standards, enforcement priorities, and vendor practices change rapidly. Confirm current requirements, effective dates, exemptions, and applicable jurisdictions before relying on this material.

Twelve steps across four stages.

The steps follow the same four stages as the governance roadmap: steps 1 to 3 are Discover, 4 to 10 are Govern, 11 is Monitor, and 12 is Educate. Repeat the cycle when tools, data, or vendors change.

For every step, record the owner, status, evidence, last review, next review, finding, and required action. Treat a checked box without evidence as unverified.

Not startedIn progressOperatingNeeds attentionNot applicable
01

Establish authority and accountability

Someone must own the program and someone must have authority to stop a use that exceeds the organization’s tolerance.

  • Name an executive sponsor and accountable program owner.
  • Define who participates in reviews and who may approve, reject, pause, or retire AI.
  • Document risk tolerance, prohibited uses, exception handling, reporting cadence, and required records.

Evidence: charter, responsibility matrix, approval authority, meeting records, exception register.

02

Discover and inventory AI

Inventory purchased, developed, embedded, and employee-selected AI, including browser tools, personal accounts, extensions, meeting assistants, copilots, APIs, and agents.

  • Record owner, purpose, users, vendor, plan, data access, integrations, permissions, and lifecycle state.
  • Identify declared and suspected Shadow AI.
  • Reconcile the register with identity, browser, expense, procurement, SaaS, network, and security records where practical.

Evidence: AI system register, discovery results, SaaS inventory, connector register.

03

Define the use case

Review the actual business process, not just the product name. The same AI tool can be low risk for drafting and high risk when it ranks applicants or takes action in another system.

  • Document the problem, benefit, users, affected people, intended use, and foreseeable misuse.
  • Identify the authoritative source of truth and define success, failure, and unacceptable outcomes.
  • Decide whether a non-AI approach could meet the need with lower risk or cost.
04

Classify data and data rights

Identify everything the AI can receive, retrieve, infer, generate, or expose. Record source, owner, permission, retention, deletion, and whether the vendor may use data for training or product improvement.

  • Apply the organization’s data classification scheme.
  • Minimize fields and remove identifiers when they are not necessary.
  • Set rules for prompts, uploads, outputs, history, memory, feedback, logs, and retrieved data.
05

Identify legal, contractual, and insurance considerations

Screen for privacy, security, employment, biometric, consumer, civil-rights, intellectual-property, accessibility, records, and sector-specific considerations. Review customer contracts, supplier terms, and insurance conditions.

Keep three classifications separate. Internal AI risk tier, data classification, and legal classification answer different questions. One does not substitute for another.
06

Review the vendor and platform

  • Identify the contracting entity and exact product plan.
  • Review security, privacy, availability, retention, deletion, training use, subprocessors, data location, and incident terms.
  • Review identity controls, logs, offboarding, export, and connector permissions.
  • Set recurring review dates and change triggers.
07

Classify and treat risk

Assign an internal tier based on impact, scale, reversibility, data sensitivity, autonomy, affected people, and uncertainty. Identify plausible failure scenarios, current safeguards, and remaining exposure.

  • Choose a response: avoid, reduce, transfer, accept, or monitor.
  • Require higher authority for higher-risk acceptance.
  • Define hard stops that prevent deployment or require immediate suspension.
08

Design meaningful human oversight

A person who clicks “approve” without enough information, time, competence, or authority is not meaningful oversight.

  • Name the person accountable for the result.
  • Define what the reviewer checks and when escalation is mandatory.
  • Provide correction, appeal, override, and service-recovery paths.
  • Log material overrides and analyze recurring patterns.
09

Evaluate before approval

  • Test task success, factual accuracy, unsupported output, and source grounding.
  • Test privacy leakage, access control, prompt injection, unsafe instructions, and foreseeable misuse.
  • Test materially different outcomes for relevant groups when people may be affected.
  • Verify logging, rollback, shutdown, and manual continuity.

Evidence: evaluation plan, representative test set, results, limitations, remediation, acceptance decision.

10

Approve and deploy

  • Record a formal go, conditional-go, pilot, or no-go decision.
  • Confirm approved users, purposes, data, integrations, settings, and locations.
  • Communicate limitations, prohibited behavior, and reporting channels.
  • Activate monitoring and set review dates before operational use.
11

Monitor and respond

Monitor new tools, sensitive-data interactions, access, connectors, errors, complaints, corrections, overrides, vendor changes, policy exceptions, and overdue reviews.

  • Integrate AI incidents with privacy, security, legal, HR, and continuity procedures.
  • Preserve logs and evidence.
  • Define containment, notification evaluation, correction, recovery, and root-cause steps.
  • Retest and reapprove after material changes or incidents.
12

Educate and continually improve

  • Provide baseline AI literacy and role-based training.
  • Teach which data is prohibited, restricted, or approved, and why.
  • Refresh training after material system, policy, threat, or regulatory changes.
  • Retire unused systems, revoke access, address retained data, and archive the decision.

Why some data requires tighter boundaries

AI can create additional copies in prompts, histories, logs, embeddings, and connected systems. It can combine fields, infer sensitive facts, or expose information through output. Consider sensitivity, identifiability, permanence, context, scale, duties, decision impact, vendor behavior, system capability, and recoverability.

Data typeWhy risk increasesStarting boundary
PublicMay still be inaccurate, licensed, outdated, or harmful when aggregated.Verify source and rights; review external output.
Internal businessCan expose operations, pricing, plans, or weaknesses.Use approved organizational accounts with access and retention controls.
Customer or employeeCan enable identification, profiling, phishing, or consequential decisions.Document purpose and permission; minimize fields; restrict and log access.
Financial or paymentCan enable direct theft, fraud, or contractual exposure.Mask or tokenize; isolate approved workflows; require specialist review.
Health or medicalCan cause lasting harm and trigger specialized duties.Confirm contracts and configuration; apply minimum necessary.
BiometricPersistent identifiers may be difficult or impossible to replace.Restrict by default; review notice, consent, retention, and deletion.
Employment or applicantCan reproduce bias and materially affect livelihood.Require human review, notice analysis, validation, correction, and appeal.
Legal or highly confidentialDisclosure can waive protections, breach duties, or expose strategy.Use only in approved matters and environments after specialist review.
Proprietary and IPCan disclose source code, methods, designs, or trade secrets.Confirm rights, training terms, access, retention, and output ownership.
Credentials and secretsCan provide immediate access to systems and records.Never enter active secrets into general-purpose AI; rotate after exposure.

Potentially applicable laws and obligations

This is an issue-spotting list, not a legal conclusion. Applicability depends on role, size, location, industry, data, affected people, and the exact use.

Illinois employment AI

May apply to Illinois employers using AI to influence recruitment, hiring, promotion, training, discipline, discharge, or other employment conditions.

Illinois AI Video Interview Act

May apply when employers request recorded interviews for Illinois-based positions and use AI to analyze them.

Illinois BIPA

May apply to private entities collecting or using covered fingerprints, voiceprints, face or hand geometry, or retina/iris scans.

Illinois PIPA

May apply to data collectors handling specified nonpublic personal information about Illinois residents or responding to a covered breach.

Federal employment laws

May apply when AI screens, ranks, monitors, evaluates, promotes, disciplines, or terminates applicants or workers.

FCRA and ECOA

May apply to consumer reports and AI-supported employment, credit, insurance, or other eligibility decisions.

HIPAA/HITECH

May apply to covered entities and business associates using AI with protected health information in covered contexts.

GLBA Safeguards Rule

May apply to covered financial institutions and service providers handling customer information.

FERPA and COPPA

May apply to covered education records or online services collecting personal information from children under 13.

FTC Act

May apply to AI claims or data practices that are unfair, deceptive, or inconsistent with privacy and security promises.

State privacy and employment rules

May apply based on resident, employee, applicant, business, and processing locations. Maintain a current state-law matrix.

GDPR and EU AI Act

May apply to EU-linked personal data or AI systems based on territorial reach, organizational role, and system classification.

Also screen customer contracts, supplier terms, insurance conditions, professional duties, and procurement requirements. They may be stricter than a general legal baseline.

Use FAIR to estimate a range, not invent a precise fine.

FAIR defines risk as probable frequency and probable magnitude of future loss. For an AI leakage scenario, estimate productivity loss, response cost, replacement cost, fines and judgments, reputation damage, and competitive-advantage loss.

  1. Define a specific loss event.
  2. Estimate how often it may create loss within a stated period.
  3. Estimate low, likely, and high loss ranges using organizational and external evidence.
  4. Record assumptions, confidence, and the date of each input.
Do not combine unlike figures. FAIR estimates, benchmark averages, statutory maximums, and past settlements serve different purposes. None is a universal “cost per leaked record.”

Move from reading to assigned owners and evidence.

The workbook includes the 48-control checklist, AI system register, vendor reviews, obligations register, incident log, and a 30/60/90-day action plan.