SC-AI-022 · Transparency

Disclose AI interaction to users

Low effortCovered by ISO 27001: New for AISatisfies 11 obligations in 8 policies

What it means

  • Tell people plainly, at the start, when they are talking to or being served by an AI system (chatbot, voice bot, AI email agent, AI-drafted reply).
  • Tell them about known limits: AI output can be wrong or unreliable, and they should verify important information.
  • Where a law or regulator requires it, offer an easy route to a human.
  • ISO 27001 reuse: None. New for AI, not covered by ISO 27001. Privacy notice processes (SOC 2 P1.1) give a starting template.

Why it matters

  • RBI FREE-AI asks regulated entities to tell customers when they are dealing with AI and to always offer a switch to a human.
  • The MeitY March 2024 advisory asks platforms to label under-tested or unreliable models and to use a consent pop-up about possible unreliability.
  • Hidden AI erodes trust fast; it also undermines any later defence that the customer knew what they were dealing with.

Checklist

  1. List every customer-facing and employee-facing touchpoint where AI talks to people (from SC-AI-003 AI system inventory).
  2. Write standard disclosure text for each channel: chat banner, voice greeting, email footer, in-app tooltip. Keep it in English plus the main regional languages you serve.
  3. Add a reliability notice for generative features ("AI can make mistakes; check important details").
  4. For beta or under-tested models, add a visible "experimental" or "may be unreliable" label and a one-time acknowledgement pop-up.
  5. Provide a visible "talk to a human" option in BFSI and other regulated journeys; test that it works (SC-AI-027 Right to contest and human review for individuals).
  6. Never let an AI agent claim to be a human, including in outbound voice calls.
  7. Add a release checklist item so new AI features cannot ship without the disclosure.
  8. Review wording yearly and after complaints.

Evidence examples

  • Screenshots of the chat banner, voice script and pop-up in production.
  • Approved disclosure text library with version history.
  • Product release checklist showing the disclosure check passed.
  • Test record showing "talk to a human" hands off correctly.
  • Consent or acknowledgement logs for the unreliability pop-up.

Common pitfalls

  • Disclosure buried in terms of service instead of shown at the point of interaction.
  • Voice bots with human-sounding names and no AI announcement.
  • Human handoff exists on paper but loops back to the bot.
  • English-only disclosures for customers served in Hindi or regional languages.

Satisfies

Also relevant to

Standards crosswalk

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

ISO/IEC 42001

  • 7.4 communication
  • A.8.2 system documentation and information for users
  • A.8.5 information for interested parties

ISO/IEC 27001

No direct equivalent

SOC 2

  • CC2.3
  • P1.1

Key takeaways

  • Say "this is AI" at the start of the interaction, in the user's language.
  • Add a plain reliability warning for generative features and label beta models.
  • In regulated journeys, a working human handoff is part of the disclosure.

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