Area 1.2

Roles and Responsibilities

Who decides what?

Baseline: 2Enhanced: 3Advanced: 1 6 controls

Who it applies to

Enter once, for the organisation as a whole. Go as deep as your organisation letter, and implement in your mode.

Why it exists

Decide who decides, before the first deployment. The most common failure in AI adoption is not technical; it is the quiet diffusion of responsibility, in which everyone assumed someone else was accountable — the vendor, the IT department, or the model itself — and no one was. Responsibility that is not pinned to a named person migrates, and it migrates toward whoever cannot be held to account. Pin it before it moves.

What to actually do

Controls

Baseline 2 controls

Control 9

Name an AI Owner for every system in the inventory.

BaselinePreventiveall rolesthe whole organisation

What it is

One accountable person per system, with the no-owner condition tracked as a key risk indicator.

How to implement it · Minimum content
  • Owner per system: name and role of a business owner, not a technologist or the provider
  • What they answer for: the system's purpose, fairness of its outcomes, and when a human must intervene
  • Named deputy for absences
  • Date assigned and the owner's written acknowledgement
  • Key risk indicator: number of systems with no owner, reported to management monthly
  • Reassignment when the owner leaves or changes role
How to start

Add an AI Owner column to the inventory, fill it for every system, and ask each person named to confirm in writing.

Evidence

The inventory with owners filled in and the history of the no-owner indicator.

Mode: light / standard / full
light
The owner-manager names the owner of each tool in the inventory spreadsheet and holds any system left unassigned.
standard
Business managers own their systems and the AI lead reports the no-owner count to management.
full
Ownership is a mandatory field in the configuration register and the no-owner count feeds the risk dashboard automatically.

Control 10

Define the escalation path for AI decisions and incidents.

BaselineCorrectiveall rolesthe whole organisation

What it is

Everyone who operates or oversees AI knows where a concern goes and who can stop a system.

How to implement it · Minimum structure
  • What to escalate: harmful or wrong outputs, data exposure, suspected misuse, complaints, breaches of red lines
  • First contact: the system's AI Owner; next level: named manager or committee
  • Who can suspend or stop a system, and how quickly (e.g. the same day)
  • Contact channel and expected response time for each level
  • How each escalation and its outcome is recorded
  • One-page summary sent to everyone who operates or oversees AI
How to start

Write one page that answers “who do I tell, and who can switch it off?” and send it to everyone who uses or oversees AI.

Evidence

The published escalation path and the log of escalations handled.

Mode: light / standard / full
light
Every concern goes straight to the owner-manager, who can switch off any tool; a shared email inbox records them.
standard
AI Owners handle first-level concerns and escalate to the AI lead, who holds the authority to suspend.
full
Escalations run through the incident-management process, with defined levels, response times and a documented suspension authority.

Enhanced 3 controls

Control 11

Maintain a stakeholder map per AI system, covering internal and external parties.

EnhancedPreventiveall rolesthe whole organisation

What it is

Reviewed when the system’s scope or reach changes.

How to implement it · Minimum content
  • Internal parties: business owner, operators, security, privacy, legal, HR, procurement
  • External parties: provider, customers and individuals affected, sector regulators
  • Wider reach where relevant: communities touched, inclusion, misinformation and environmental-cost concerns
  • For each party: how the system affects them and their main concern
  • How each party is consulted or informed, and the contact
  • Review date, and review whenever the system's scope or reach changes
How to start

For the system that affects the most people, hold a 30-minute session with its AI Owner and list everyone inside and outside the organisation who has a stake in it.

Evidence

The dated stakeholder maps and their review history.

Mode: light / standard / full
light
The AI Owner keeps a short table per system in the inventory spreadsheet.
standard
A common template is used and the map is checked at each approval and scope change.
full
Maps are held with the system record, reviewed by the governance function and used to plan consultation for high-risk systems.

Control 12

Maintain a responsibility matrix across the AI lifecycle.

EnhancedPreventiveall rolesthe whole organisation

What it is

For each stage — from request to retirement — record who is responsible for doing the work, who is accountable for the outcome, who must be consulted, and who must be informed; this is what makes diffusion of responsibility visible before it does harm.

How to implement it · Minimum structure
  • Rows: each lifecycle stage — request, evaluation, approval, deployment, monitoring, retirement
  • Columns: AI Owner, Technology Owner, security, privacy, legal, HR, procurement, provider, committee or management
  • Each cell: responsible (does the work), accountable, consulted or informed
  • Exactly one accountable person per stage; no stage without one
  • Explicit line: accountability for impact stays with the organisation, never with the provider
  • Version, approval and review whenever roles or the lifecycle change
How to start

Draft the matrix on one page for the six lifecycle stages and test it against the last system you put live.

Evidence

The approved matrix and its version history.

Mode: light / standard / full
light
A one-page table in which the same person may appear in several columns, but every cell that needs a name has one.
standard
The AI lead maintains the matrix and management approves it.
full
The governance function maintains the matrix per system class, linked to role descriptions and checked in internal audits.

Control 13

Document how the roles scale in your organisation.

EnhancedPreventiveall rolesthe whole organisation

What it is

Which accountabilities are combined in which people today, and what triggers their separation as you grow.

How to implement it · Minimum content
  • Every accountability: AI Owner, Technology Owner, governance lead, independent security reviewer, privacy, escalation authority
  • Today's holder of each, showing which are combined in one person
  • Combinations not allowed even when small (e.g. AI Owner and Technology Owner of the same system)
  • Triggers for separating roles (e.g. headcount, number of AI systems, first high-risk system)
  • Confirmation that no accountability is left without a holder
  • Review date, at least annually
How to start

List each accountability and write today's holder next to it; mark any without a holder and assign it.

Evidence

The dated role-scaling document approved by management.

Mode: light / standard / full
light
A half-page table kept by the owner-manager, updated when someone joins or leaves.
standard
The AI lead maintains it and management reviews it annually.
full
The governance function maintains it with HR, linked to the organisation chart and role descriptions.

Advanced 1 controls

Control 14

Separate building from security sign-off.

AdvancedPreventiveall rolesthe whole organisation

What it is

The person or team that certifies a system safe for launch is organisationally independent of the one that built or procured it.

How to implement it · Minimum rules
  • The security sign-off is given by a person or team outside the reporting line of those who built or procured the system
  • Builders and buyers cannot approve their own system's security
  • Before go-live the reviewer models attacks, tests adversarially and assesses impact on people's rights
  • The reviewer can withhold sign-off; overriding it requires a recorded decision at committee or board level
  • Conflicts of interest declared and recorded at each sign-off
How to start

Name the function that will give security sign-off and confirm in writing that it does not report to the people who build or buy AI.

Evidence

Sign-off records showing the reviewer's independence and findings.

Mode: light / standard / full
light
Commission an external reviewer for each launch, since internal separation is not possible at this size.
standard
The security team, separate from delivery and procurement, signs off each launch.
full
A dedicated independent AI security function, reporting outside the technology line, signs off and can be overridden only by the board.

Evidence

The stakeholder maps; the responsibility matrix; owner assignments in the inventory; role descriptions; the written non-delegation statement; evidence of independent security review.