SC-AI-002 · Governance

AI roles, accountability and oversight committee

Medium effortCovered by ISO 27001: StrongSatisfies 20 obligations in 9 policies

What it means

  • Every AI system has a named business owner who answers for it, and the company has a group (committee or existing risk committee) that oversees AI risk as a whole.
  • Roles are written down: who approves new AI uses, who validates models, who monitors them, who handles incidents, who signs off on vendor AI.
  • Staff have a clear route to raise concerns about an AI system (for example unfair outcomes or misuse) without fear of blame.
  • Where AI is supplied by or to a partner, the contract and RACI say which side is responsible for what.

Why it matters

  • RBI FREE-AI puts AI risk under the Risk Management Committee and suggests a cross-functional AI committee.
  • When something goes wrong, "the model did it" is not an answer. Regulators and customers want a person who was accountable.
  • Clear roles stop the gap where IT thinks business owns the model and business thinks IT does.

Checklist

  1. Decide where AI oversight sits: existing RMC, a new AI committee, or both. Write terms of reference (members, quorum, frequency, decisions it can take).
  2. Include risk, compliance, legal, IT/security, data, and business heads on the committee.
  3. Build a RACI for the AI lifecycle: intake, risk assessment, build or buy, testing, approval, deployment, monitoring, incidents, retirement.
  4. Assign a business owner and technical owner for every system in the SC-AI-003 AI system inventory.
  5. Keep developers and validators separate for medium and high risk systems.
  6. Set up a channel to report AI concerns (email alias, ethics hotline category, or ticket type) and tell staff about it.
  7. For partner or vendor AI, record the split of responsibilities in contracts.

Evidence examples

  • AI committee terms of reference approved by the board, and the last four sets of meeting minutes.
  • RACI matrix for the AI lifecycle, version-controlled.
  • Inventory extract showing named owners for each AI system.
  • Job descriptions or appointment letters naming the AI risk owner.
  • Concern-reporting channel communication and a log of concerns raised and closed.

Common pitfalls

  • Committee exists on paper but never meets, or meets without minutes.
  • Owners named as teams ("Data Science") rather than people.
  • Same person builds, tests and approves a high-risk model.
  • No path for frontline staff to flag a misbehaving AI tool.

Satisfies

Also relevant to

Standards crosswalk

Clause references only. Check the standard itself for the exact wording.

ISO/IEC 42001

  • 5.1 Leadership and commitment
  • 5.3 Roles, responsibilities and authorities
  • A.3.2 AI roles and responsibilities
  • A.3.3 Reporting of concerns
  • A.10.2 Allocating responsibilities

ISO/IEC 27001

  • A.5.2 Information security roles and responsibilities
  • A.5.3 Segregation of duties
  • A.5.4 Management responsibilities

SOC 2

  • CC1.2
  • CC1.3
  • CC1.5

Key takeaways

  • Name a person for every AI system and a forum for AI risk overall.
  • Partial reuse from ISO 27001: the roles, segregation of duties and management responsibility patterns carry over; the AI committee and concern-reporting channel are new.
  • Write down responsibility splits with vendors and partners before go-live.

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