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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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 type | Why risk increases | Starting boundary |
|---|---|---|
| Public | May still be inaccurate, licensed, outdated, or harmful when aggregated. | Verify source and rights; review external output. |
| Internal business | Can expose operations, pricing, plans, or weaknesses. | Use approved organizational accounts with access and retention controls. |
| Customer or employee | Can enable identification, profiling, phishing, or consequential decisions. | Document purpose and permission; minimize fields; restrict and log access. |
| Financial or payment | Can enable direct theft, fraud, or contractual exposure. | Mask or tokenize; isolate approved workflows; require specialist review. |
| Health or medical | Can cause lasting harm and trigger specialized duties. | Confirm contracts and configuration; apply minimum necessary. |
| Biometric | Persistent identifiers may be difficult or impossible to replace. | Restrict by default; review notice, consent, retention, and deletion. |
| Employment or applicant | Can reproduce bias and materially affect livelihood. | Require human review, notice analysis, validation, correction, and appeal. |
| Legal or highly confidential | Disclosure can waive protections, breach duties, or expose strategy. | Use only in approved matters and environments after specialist review. |
| Proprietary and IP | Can disclose source code, methods, designs, or trade secrets. | Confirm rights, training terms, access, retention, and output ownership. |
| Credentials and secrets | Can 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.
- Define a specific loss event.
- Estimate how often it may create loss within a stated period.
- Estimate low, likely, and high loss ranges using organizational and external evidence.
- Record assumptions, confidence, and the date of each input.
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.
