Scale What You Do to Who You Are and What You Are Doing
Are we doing more — or less — than our situation actually requires?
Baseline: 2Enhanced: 13 controls
Who it applies to
Enter for every AI system. Go as deep as your system letter, and implement in your mode.
Why it exists
Apply each obligation at the depth your situation demands, no more and no less — because a framework applied uniformly is wrong for almost everyone. Held to the same standard, the demands that are prudent for a bank training its own model would crush a small firm buying a subscription, and the light touch appropriate for that small firm would be reckless for the bank. Proportionality is what makes one framework fit both. It is not a discount or a licence to skip; it is the deliberate calibration of every requirement to the factors that actually determine risk.
What determines your level
Three questions decide what applies to you, and they are independent of one another. Relevance — which controls concern you at all — is decided by your role with respect to each system (consumer, deployer, developer; roles add up), fixed by the sourcing decision of Domain 1, and by the properties of each use: whether it decides about people, whether the AI acts, whether it processes personal data. Depth — the tier at which each relevant control applies — is decided by the criticality of the use and the rules that bind you: the class of each use (minimal or limited → Baseline; high-risk → Advanced), its criticality (low → Baseline; medium → Enhanced; high → Advanced), and the rules you operate under (general data-protection law only → Baseline; sector regulation, or deployer obligations under an AI-specific regime → Enhanced; provider obligations for high-risk or general-purpose AI → Advanced), read from the applicability map. For each system, the depth is the strongest of those three; for organisation-scoped obligations — the committee, the security programme, the responsibility matrix, the indicator set — it is set by the rules that bind you. A consequential use therefore raises the obligations attached to that system to the top, but does not by itself oblige a small organisation to constitute a committee at Advanced. Your role does not raise the depth: building a low-stakes internal classifier does not put you at Advanced, and using a purchased tool to shortlist job applicants puts that system at Advanced although you built nothing. Mode — how you meet each applicable control — is decided by your size and capacity: light (micro and small), standard (medium), full (large), as the table below defines for the obligations most often made applicable to small organisations. Size never removes a control. Your current maturity decides only the sequence: the gap between the applicable controls and those already evidenced is your plan, and the first-stage scope of “Where to start” is its head. In short: role determines relevance, criticality determines depth, and size determines the mode of implementation.
Light mode for obligations a consequential use raises on a small organisation
Area
Obligation (tier)
Light mode (micro / small)
Standard / full mode
1.3
AI committee with go-live gate (E)
Escalation path to the owner-manager, who signs the go-live decision for each person-affecting use
Cross-functional committee with HR and DPO; federated governance with board reporting
1.2
Responsibility matrix (E)
One page naming who owns, who checks, who can stop each system; hats combined, none deleted
Full RACI per lifecycle stage; separated functions
1.11
AI security programme (E)
Named person; budget line for one external test a year
Annual adversarial test of each high-demand system with published test batteries or an external tester
Recurring red-team programme across the estate
2.3
AI-specific vulnerability testing (E)
Provider’s published results plus your own injection and swap tests on your integration
In-house or contracted testing on every change
3.2 / 9.2
Unified impact assessment (E)
Two pages covering purpose, affected people, possible harms and mitigations, signed by the owner-manager
Full assessment with rights and privacy sections, reviewed by the data-protection officer and legal
4.6
Fairness metrics (E)
Swap test plus quarterly selection-rate check on a spreadsheet
Metric pipeline on evaluation set and outcomes; per-group reporting
4.6
Independent bias audit (A)
Commissioned annual audit of the one system, or the provider’s audit where the tool is unmodified and covers your use
Annual independent audit of each covered system
6.2
Oversight interface equips override (E)
Reviewer sees the criteria and the rejected list, not only the ranking; a note field records overrides
Designed oversight interface with confidence and alternatives
7.1 / 7.2
Drift and wrong-behaviour monitoring (E)
Monthly sample review against criteria; a provider model-change notice triggers a re-test
Automated monitoring with thresholds and alerts
9.3
Per-system threat register (E)
One page listing the threats that apply and the control that treats each
Maintained register of named threats per system, reviewed on change
What to actually do
Determine your profile, and let it decide what applies and how deep. Establish your role, the properties, class and criticality of each use, the rules that bind you, your size, and your maturity. Your role and the properties of your uses decide which obligations are relevant; the criticality of each use and your rules decide the tier at which each applies; your size decides only how you meet them. The rules are explicit and reproducible — two organisations with the same profile land on the same obligations — but the inputs are judgements: record how you classified each use and why a rule does or does not apply, so the reading can be reviewed.
Never let ‘small’ become an excuse to skip the Baseline. Proportionality scales how you meet an obligation and how far you extend it; it never removes the Baseline, which every organisation running AI meets regardless of size. A small organisation does less than a large one — but not less than the floor.
Re-derive the profile when your situation changes. A change of role — beginning to fine-tune a model, entering a regulated use — or a change in the rules that apply to you moves your profile and therefore your obligations. Re-read the profile on those events, so the framework tracks your real exposure rather than the one you had at first adoption.
Controls
Baseline2 controls
Control 233
Determine and record your profile across the six determining factors.
BaselinePreventiveall rolesper system
What it is
Role, rules, use class, criticality, size, and maturity — the basis for every tier decision.
How to implement it · Minimum content
Role per system: consumer, deployer, developer (roles add up)
Rules that bind you: general data-protection law only; sector or AI-specific deployer obligations; provider obligations for high-risk or general-purpose AI
Use class and properties: minimal, limited or high-risk; decides about people, AI acts, processes personal data
Criticality of each use: low, medium or high
Size: micro or small, medium, large (sets light, standard or full mode)
Maturity: controls already evidenced
Reason for each classification, who recorded it and date
How to start
Add these columns to the inventory spreadsheet and fill one row per AI system, with a one-line reason per classification.
Evidence
The recorded profile per system with the reasons for each classification.
Mode: light / standard / full
light
The owner-manager fills the columns in one sitting, with an adviser if needed.
standard
The AI lead completes it with each system owner; management confirms.
full
The governance office keeps it in the inventory system; legal confirms rules, risk confirms criticality.
Control 234
Derive relevance from your role and uses, and depth from criticality and rules.
BaselinePreventiveall rolesper system
What it is
Recorded per system; size sets only the mode of implementation; the Baseline is never waived.
How to implement it · Steps
Relevance: from the system's role and properties, select the controls that concern it
Depth: take the strongest of use class (minimal or limited → Baseline; high-risk → Advanced), criticality (low/medium/high → Baseline/Enhanced/Advanced) and rules
Organisation-wide obligations (committee, security programme, responsibility matrix, indicators): depth from the rules alone
Mode: from size alone; it changes how a control is met, never whether
Keep every Baseline control, whatever the result
Record the derivation per system so it can be reviewed
How to start
For each system in the profile, write its resulting tier and a one-line reason naming which factor set it.
Evidence
The derivation record per system, showing relevance, tier and the factor that set it.
Mode: light / standard / full
light
The owner-manager writes tier and reason next to the profile in the spreadsheet.
standard
The AI lead derives tiers and a second person checks the reasoning.
full
The governance office applies a documented method, reviewed by risk and legal.
Enhanced1 controls
Control 235
Re-derive the profile on material change of role or applicable rules.
EnhancedPreventiveall rolesper system
What it is
So obligations track real exposure over time.
How to implement it · Minimum rules
Role triggers: starting to fine-tune or train a model; integrating others' models into your own product
Use triggers: a system starting to decide about people, or entering a regulated use
Rules triggers: new applicable rules, amendments, or a new jurisdiction where systems produce effects
On a trigger: re-run the profile and derivation for affected systems before the change goes live
Compare old and new tiers; add new gaps to the implementation plan
Log trigger, date, result and who reviewed it
How to start
Add the question 'does this change our role or the rules that apply?' to the project-approval and change forms.
Evidence
The re-derivation records against each change event, with the resulting plan updates.
Mode: light / standard / full
light
The owner-manager re-reads the profile row on any trigger and notes the result.
standard
Project and legal contacts notify the AI lead, who re-runs the derivation.
full
Change management and regulatory watch open re-derivation tasks automatically.
Evidence
The recorded organisational profile; the derivation of tiers from it; re-derivation records against change events.