Area 7.3

Log Enough to Reconstruct and Audit — No More

Can we reconstruct what the system did, without creating a new privacy problem by doing so?

Baseline: 1Enhanced: 2 3 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

Keep records detailed enough to reconstruct and audit the system’s behaviour, at a depth proportionate to the stakes — and no deeper, because the logs themselves become a store of personal data you must then protect and delete. There is a real tension here: accountability wants everything kept forever; privacy wants the minimum kept for the shortest time. Resolve it deliberately per system, rather than defaulting to logging everything and discovering later that your audit trail is also your largest uncontrolled personal-data store.

What to actually do

Controls

Baseline 1 controls

Control 207

Log AI interactions at a basic depth.

BaselineDetectiveall rolesthe whole organisation

What it is

Who, when, which system and version, and input and output identifiers — using the provider’s audit logs where available and exporting them to storage you control.

How to implement it · Minimum content
  • Who: the user account that made the interaction
  • When: date and time
  • Which system, and its version where available
  • Input and output identifiers: references, not necessarily the full content
  • Source and storage: the provider's audit log where available, exported regularly to storage the organisation controls
How to start

Check each AI tool's administration settings for an audit log, switch it on, and schedule a monthly export to company storage.

Evidence

The exported interaction logs covering all AI tools in use.

Mode: light / standard / full
light
The administrator downloads each provider's log monthly to a company folder; tools without logs are noted in the inventory.
standard
Scheduled automatic export of provider logs to central storage, managed by IT.
full
Logs streamed continuously into the central logging platform and correlated with other security logs.

Enhanced 2 controls

Control 205

Log at a depth proportionate to the stakes, sufficient to reconstruct and audit.

EnhancedDetectiveall rolesper system

What it is

Decided per system, not defaulted to maximal capture.

How to implement it · Minimum structure
  • Stakes level of the system and the reason for it
  • What is logged: for high stakes, inputs, outputs, versions and human involvement; for low stakes, metadata only
  • What is deliberately not logged, e.g. full prompts containing personal data where not needed
  • Where the logs are kept and who can access them
  • Reconstruction test: one decision rebuilt from the logs
How to start

Write the logging decision for this system on one page, then check it by reconstructing one recent decision from what is actually logged.

Evidence

The per-system logging decision with its rationale and a demonstrated reconstruction.

Mode: light / standard / full
light
A short note per system, written by its owner, relying on the provider's logs.
standard
A logging decision per system agreed by the system owner and IT, with a reconstruction check.
full
A logging standard by stakes level, applied per system and verified by internal audit.

Control 206

Apply privacy retention and deletion to the logs.

EnhancedPreventiveall rolesper system

What it is

The audit trail is a governed personal-data store.

How to implement it · Minimum rules
  • Retention period per log type, set from the audit need, never indefinite
  • Automatic deletion or anonymisation when the period ends
  • Erasure requests reach the logs: searchable by person identifier
  • Personal data fields not needed for audit masked at capture
  • Access restricted to named roles, and access itself logged
  • Deletion suspended for logs tied to an open dispute or incident
How to start

Find where this system's logs are stored, set a retention period for each type, and switch on automatic deletion.

Evidence

The retention schedule for the logs and evidence of deletion and of erasure requests applied to them.

Mode: light / standard / full
light
The provider's log-retention setting configured, and exported logs deleted by the owner on a calendar reminder.
standard
Retention and deletion rules configured in log storage, managed by IT with the privacy lead.
full
Logs included in the data-retention programme, with automated deletion, erasure workflows and periodic audit.

Evidence

The per-system logging decisions and their rationale; the logs’ retention and deletion governance; a demonstrated reconstruction from them. The basic interaction logs and their export.