Area 1.3

AI Committee

Who oversees AI?

Enhanced: 5Advanced: 1 6 controls

Who it applies to

Enter once, for the organisation as a whole when your organisation letter is E or A (this area has no Baseline controls). Go as deep as your organisation letter, and implement in your mode.

Why it exists

Give AI a single body that oversees it across the whole organisation. AI decisions cut across functions — a hiring tool is simultaneously a technology choice, a legal exposure, a privacy question, and a workforce matter — and decisions that cut across functions, taken inside any single function, are decided with blind spots. The committee exists to remove them. If your organisation is small and has no board or committee culture, do not fabricate one: a defined escalation path to the owner-manager fulfils this dimension, and pretending otherwise produces theatre, not oversight. That exemption is deliberate and applies only while you remain small.

What to actually do

Controls

Enhanced 5 controls

Control 15

Establish the committee with a written mandate.

EnhancedPreventiveall rolesthe whole organisation

What it is

The mandate states its authority — including the go-live gate — its composition, and its scope.

How to implement it · Minimum structure
  • Purpose and scope: all AI use across the organisation
  • Authority: go-live gate for high-risk systems, with power to block or suspend
  • Composition: technology, security, legal, privacy, HR, the business, the AI lead; named chair
  • Quorum and decision rule
  • Standing agenda: high-risk approvals, workforce impact, provider concentration, incidents
  • Reporting line and frequency of reports to the board
  • Approval by the board and annual review of the mandate
How to start

Draft a two-page mandate with these sections and have the board, or the highest available authority, approve it.

Evidence

The approved mandate and its version history.

Mode: light / standard / full
light
No committee is constituted; a written escalation path to the owner-manager replaces it, and the owner-manager signs each go-live for a person-affecting use.
standard
A compact committee of existing managers works under the mandate and reports to management.
full
A formal committee with a secretariat, terms of reference approved by the board, and regular reporting to it.

Control 16

Set a meeting rhythm and keep it.

EnhancedPreventiveall rolesthe whole organisation

What it is

A committee that meets when convenient governs nothing; the rhythm is fixed and attendance is tracked.

How to implement it · Minimum rules
  • Fixed frequency set in the mandate (e.g. monthly or quarterly), with dates published for the year
  • Extraordinary meeting route for urgent go-live decisions or incidents
  • Agenda sent in advance; minutes with decisions and actions issued within a set period (e.g. one week)
  • Attendance recorded per seat, with named substitutes
  • Cancelled meetings and repeated absences reported to the chair and the board
How to start

Publish the meeting calendar for the next 12 months and send the invitations now.

Evidence

The calendar, minutes and attendance records.

Mode: light / standard / full
light
No committee is constituted; the owner-manager reviews AI matters at a fixed point in an existing management meeting and notes the decisions.
standard
The committee meets on a fixed cycle, with a rotating secretary taking minutes and attendance.
full
A secretariat runs the calendar, minutes, action tracking and attendance reporting to the board.

Control 17

Keep the composition multidisciplinary, including HR and the data-protection officer.

EnhancedPreventiveall rolesthe whole organisation

What it is

Absences in those two seats are treated as gaps to close, not as scheduling accidents.

How to implement it · Minimum content
  • Seats: technology, security, legal, privacy (the data-protection officer), HR, the business, the AI lead
  • For each seat: named holder and named deputy
  • Attendance per seat at each meeting
  • Gap log: any HR or data-protection officer absence recorded with an action and date to close it
  • Annual review of composition against the systems the committee oversees
How to start

Check the current membership against the seat list and invite HR and the data-protection officer, with deputies, if either seat is empty.

Evidence

The membership list with deputies, attendance records and the gap log.

Mode: light / standard / full
light
No committee is constituted; the owner-manager consults whoever handles HR and data protection, internal or external, before each person-affecting go-live.
standard
Each seat is held by an existing manager, with deputies named and absences followed up by the chair.
full
Seats are formally assigned in the mandate, attendance is reported to the board and persistent gaps are escalated.

Control 18

Review the workforce impact of any AI affecting employees or applicants.

EnhancedPreventiveall rolesthe whole organisation

What it is

A standing review, owned jointly with HR, before such systems launch and periodically after.

How to implement it · Steps
  1. Trigger: any AI used to hire, evaluate, allocate tasks to or monitor employees or applicants
  2. Describe the use, the decisions it influences and who is affected
  3. Assess fairness, risk of discrimination, proportionality of any monitoring and fit with employer obligations
  4. Conclude jointly with HR: approve, approve with conditions, or reject, before launch
  5. Re-review periodically (e.g. annually) and on any change of use
How to start

List every AI that touches employees or applicants, including features inside HR software, and schedule the first review with HR.

Evidence

The workforce-impact review records and their conclusions.

Mode: light / standard / full
light
No committee is constituted; the owner-manager and whoever handles HR complete a short checklist before launch and once a year.
standard
The committee runs the review with the HR manager and records the conclusion in its minutes.
full
A structured review led jointly by the committee and HR, with input from employee representatives where they exist.

Control 19

Track provider concentration and exit readiness.

EnhancedDetectiveall rolesthe whole organisation

What it is

The committee maintains a current view of single-supplier dependencies and their exit cost.

How to implement it · Minimum content
  • Capability or process, and the provider or providers it depends on
  • Single-supplier flag
  • Impact if the provider fails, changes terms or withdraws a model
  • Exit option (alternative provider, in-house, manual fallback) with estimated time and cost
  • Contract exit terms: notice period, data return, portability
  • Review date; the view is presented to the committee at least quarterly
How to start

From the inventory, list each AI provider and count how many processes depend on it alone.

Evidence

The concentration and exit-readiness view and the minutes where it was reviewed.

Mode: light / standard / full
light
No committee is constituted; the named owner keeps a short provider list with a manual fallback noted for each critical process.
standard
Procurement and the AI lead maintain the view and present it to the committee.
full
The view is part of third-party risk management, with exit plans tested for the most critical dependencies.

Advanced 1 controls

Control 20

Maintain a regulatory watch.

AdvancedDetectiveall rolesthe whole organisation

What it is

The committee tracks the AI rules applicable in every jurisdiction where you operate, and turns changes into actions.

How to implement it · Minimum content
  • Jurisdictions where the organisation operates or where its AI reaches people
  • Sources per jurisdiction: official journals, regulator publications, sector associations, legal advisers
  • Per rule: what it requires, when it applies, which systems it affects (linked to the applicability map)
  • For each change: action, owner, deadline and status
  • Cadence: monthly scan, quarterly summary to the committee
How to start

List the jurisdictions you operate in and assign one named person to check the official sources monthly.

Evidence

The source-linked regulatory tracker and the actions raised from it.

Mode: light / standard / full
light
No committee is constituted; the named owner keeps the watch and the applicability map, possibly through a commissioned update service.
standard
Legal or compliance keeps the tracker and reports changes to the committee.
full
A dedicated regulatory function maintains the tracker across jurisdictions, with change actions tracked to closure.

Evidence

The mandate; minutes and attendance; workforce-impact reviews; the concentration and exit-readiness view; decision and action logs; go-live authorisations and refusals. The applicability map per system (Domain 10, Dimension 3). A maintained, source-linked regulatory tracker is an acceptable means of operating the regulatory watch.

Light mode

How a small organisation meets it.

The named owner keeps the applicability map and the regulatory watch; no committee is constituted, and the owner-manager signs each go-live decision for a person-affecting use.