Area 3.1

Know What Personal Data Your AI Touches

Whose information does this system see, and where does it go?

Baseline: 1Enhanced: 2 3 controls

Who it applies to

Enter for every AI system. Some of its controls apply only where it processes personal data (B4). Go as deep as your system letter, and implement in your mode.

Why it exists

Map the personal data across the whole life of the system, not only its main store. For every AI system, establish what personal information it processes and at which stage: the data it was trained or adapted on, the data it consults to answer, and — the two that are always missed — the data that arrives in the prompts people type into it and the data that accumulates in the logs it keeps. You cannot protect, minimise, or delete what you have not located, and the located inventory is the foundation every other dimension of this domain builds on.

What to actually do

Controls

Baseline 1 controls

Control 147

Maintain a per-system record of the personal data processed at each stage.

BaselinePreventiveall rolesper systempersonal-data

What it is

Training, consultation, prompting, and logging — the last two included by default, not on request.

How to implement it · Minimum content
  • Stage: training or adaptation data, consulted sources, prompts and uploads from users, logs and stored histories
  • Personal data categories at each stage (e.g. names, contact details, financial, health)
  • Whose data: customers, staff, applicants, third parties named in documents
  • Where it is stored and for how long, including on the provider's side
  • Record owner and date of last review
How to start

For each AI system, ask its owner four questions — what trained it, what it looks up, what users type or upload, what its logs keep — and fill one row per stage.

Evidence

The per-system record with all four stages completed, prompts and logs included.

Mode: light / standard / full
light
One spreadsheet tab per system, filled by the person who manages the tool, using the provider's documentation for training and log details.
standard
The system owner keeps the record alongside the AI inventory and the privacy lead checks it before each go-live.
full
The privacy function keeps the records in its privacy register, partly fed by automated data-flow discovery, and reviews them on every change.

Enhanced 2 controls

Control 148

Include derived numeric stores in the personal-data inventory.

EnhancedPreventiveall rolesper system

What it is

Treated as personal data wherever they are built from it.

How to implement it · Minimum content
  • Store identifier and the system that uses it (e.g. the document index a search assistant consults)
  • Source data it was built from and the personal data categories it carries over
  • How it is refreshed when the source data changes or is deleted
  • Access and retention, matching those of the source data
  • Link to the source entry in the per-system personal-data record
How to start

List every place where documents or records are converted into numeric representations for search or comparison, and mark each as personal data wherever any of its sources is.

Evidence

Inventory entries for each derived store with its source data and personal data categories.

Mode: light / standard / full
light
Ask the provider or integrator which indexes the tool builds from your documents and add each to the record.
standard
The system owner registers each derived store when it is built, as an item on the deployment checklist.
full
Derived stores are discovered from the platform configuration and registered in the privacy register with their lineage to source data.

Control 149

Tag every AI asset with its personal data and governing rules.

EnhancedPreventiveall rolesper system

What it is

Carried in the Governance inventory, kept current as the system changes.

How to implement it · Minimum content
  • Personal data categories the asset touches, taken from the per-system record
  • Special categories present: health, ethnic origin, beliefs, biometrics, data on minors
  • Data subjects: customers, staff, applicants, members of the public
  • Governing rules: applicable data-protection law, contractual and sector confidentiality duties, internal retention rules
  • Date of last update, refreshed on any change of model, data source or purpose
How to start

Add personal-data and governing-rule columns to the existing AI inventory and fill them from the per-system personal-data records.

Evidence

The AI inventory with completed privacy tags and its change history.

Mode: light / standard / full
light
Two extra columns in the inventory spreadsheet, updated by the person who keeps it whenever a tool changes.
standard
The inventory owner updates the tags as part of change approval and the privacy lead checks them each quarter.
full
The tags are mandatory fields in the asset-management system, validated by the privacy function and synchronised with the privacy register.

Evidence

The per-system personal-data records; the inventory tags; the identification of derived stores holding personal data.