AI Tool Approval & Data Permission Matrix
States which AI tools are approved and which data classifications each may process.
Available soon
- Format
- Excel
- Size
- 75 KB
- Length
- 11 sheets
- Version
- 1.1
- Updated
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What's inside
What changed
- 1.1
Internal data, like Confidential, needs a contract term that bars the supplier from training on it, as the information classification standard's CL-19 requires; a setting verified off is an added control and no longer enough on its own. The grid, the check and the example's warehouse forecasting module follow it.
- 1.0
Published.
Preview
The workbook's sheets as you will receive them, with its example rows and the values its formulas calculate. Highlighted [[text]] is for you to replace; rows marked EXAMPLE are for you to delete. Wide sheets scroll sideways. The cover, document control and changelog sheets are in the file.
Instructions
How to use this workbook
| Step | What to do |
|---|---|
| 1 | Read the Data Rules sheet first. It sets the three states of a tool, the baseline conditions (BC-1 to BC-5), the supplier terms (ST-1 to ST-8) and what decides each class of data. They come from the AI Acceptable Use & Security Policy (AG-02, AG-03, AG-04, AG-11) and from the classification levels of P15. |
| 2 | Open the Approved Tools sheet. Replace the EXAMPLE rows with your tools: one row for each AI tool, and one for each AI feature built into a service you already use. Fill only the yellow cells. The four data columns, the personal data column and the review status calculate. |
| 3 | Add or change a row only after an intake decision under the AI Use Case Intake & Approval Procedure (IS-5), and record it in the AI System & Use Case Inventory. A tool with no row is not approved. A tool in the state Not approved takes Public information with no personal data in it only, and never through a work account. |
| 4 | Set the state and the highest level from the decision. Fill in what the baseline asks about: how people sign in, how training on your data is barred (a contract term, needed for Internal and Confidential data; a setting verified off is an added control, checked at each review, and never a substitute), the supplier's decision under P06, and whether the tool is approved for personal data. If any of these is missing, the tool cannot take that level. The grid shows it. A tool list carried over from an older template that has Yes or No in the training column must be changed to Contract term, Setting verified off or None. |
| 5 | Write each further condition in its own line in the Further conditions column. A condition with a date is a condition of the approval, and the tool is switched off if it is not met. |
| 6 | Answer a staff question on the Check a Use sheet: choose the tool, the class of data and whether it includes personal data. Give staff the grid (the four data columns of the Approved Tools sheet) and nothing else from this workbook. |
| 7 | Run the Test Cases sheet after you change anything. Every row must say Agrees. Add a row for any case your staff ask about. Do not overwrite a formula. |
| 8 | Review each approval at the interval its tier sets (Data Rules sheet), and within [[10]] working days of a trigger. Take the review date from the inventory. Set the as-at date on the Check a Use sheet. Delete the EXAMPLE and TEST rows before approval. |
Legend
Yellow cells are inputs. Everything else is calculated or fixed — do not overwrite formulas.
| EXAMPLE | Rows marked EXAMPLE in the first column show how a completed row looks. Delete them before approval. |
This document helps you govern the AI your organisation uses. It is not legal advice, and following it is not a statement that you comply with the EU AI Act, the GDPR or any standard. Whether the Act binds you, in which role, and which of its duties apply to each system depends on the facts and on how your Member State applies the Act: confirm it with counsel.
Public information with no personal data in it may go into any tool (P15 CL-19), but never through a work account and never under the organisation's name (AG-02). Personal data inside Public information needs a tool approved for personal data (BC-5). Special category personal data never goes into an AI tool. No row, state or condition changes either rule, and neither takes an exception (AG-20).
EXAMPLE: a wholesale distributor with about 900 staff, three warehouses and an online ordering service that takes 60% of its orders, Q3 2026. Its six tools are on the Approved Tools sheet as at 30 Sep 2026. Values marked [[like this]] are yours to set. Rows marked TEST on the Test Cases sheet are test inputs, not part of the example.
Tailoring for a small organisation: one person can keep the list, usually the person who holds security accountability. Keep every row and every baseline condition. A short list with six tools is enough. Do not drop a tool because it is free or built into something else.
Tailoring for a regulated organisation, such as a financial entity or a health provider: your regulator, your sector rules or your customers' contracts may bar some data from AI tools altogether, or ask for more of a supplier. Add each as a further condition on the tool. Counsel confirms which apply.
Tailoring for IT run by a service provider or outsourced to one: list every AI feature your service provider or any other supplier switches on in a service you use, as kind Built into a service. Ask the provider for the supplier terms (ST-1 to ST-8) and tell it that a new AI feature needs your approval first.
Approved Tools
One row per AI tool or built-in AI feature. Yellow cells are yours to complete. The columns marked (calc) calculate: do not type over them.
This document helps you govern the AI your organisation uses. It is not legal advice, and following it is not a statement that you comply with the EU AI Act, the GDPR or any standard. Whether the Act binds you, in which role, and which of its duties apply to each system depends on the facts and on how your Member State applies the Act: confirm it with counsel.
| Row | Tool ID | AI tool or built-in AI feature | Kind | Supplier (P06 reference) | State | Highest data level approved | Approved for personal data? | How people sign in | How the supplier is barred from training on our data | Supplier's decision under P06 | Further conditions | Uses that rely on it (A05) | Review by | Public data (calc) | Internal data (calc) | Confidential data (calc) | Special category data (calc) | Personal data may go in up to (calc) | Review status (calc) |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| EXAMPLE | T-01 | Office suite assistant (writing and summarising) | Tool staff use | SUP-005 | Approved with conditions | Internal | No | SSO | Contract term | Approve | No personal data, customer price lists or other Confidential files. A person reads every output before it is sent or published. Meeting transcription stays switched off until the Data Protection Officer has reviewed it. | AI-001 | 2 Sep 2027 | May | May | Must not | Must not | None | In date |
| EXAMPLE | T-02 | Warehouse system forecasting module | Built into a service | SUP-010 | Approved with conditions | Internal | No | Local accounts | Contract term | The supplier's assessment under P06 TP-05 ends in Approve or Approve with conditions by 2026-10-20; if not, the module is switched off. The contract amendment signed on 23 Sep 2026 bars the supplier from training its models, or other customers', on our stock data (ST-1). The module's setting that shares data for model improvement also stays off and is checked at each review. An inventory planner reviews every reorder proposal before it is placed. | AI-002 | 28 Mar 2027 | May | May | Must not | Must not | None | In date | |
| EXAMPLE | T-03 | Design tool image generator | Tool staff use | [[P06 reference of the design tool supplier]] | Approved with conditions | Public | No | SSO | Setting verified off | Public information only. No realistic images of real people, our sites or our products; any realistic generated image is labelled (AG-08; EU AI Act Article 50(4)). Marketing lead signs off every published image. | AI-004 | 23 Sep 2027 | May | Must not | Must not | Must not | None | In date | |
| EXAMPLE | T-04 | Free public chat assistant (personal accounts) | Tool staff use | None | Not approved | Public | No | Personal | None | None | AI-005 | May | Must not | Must not | Must not | None | Not approved: no review | ||
| EXAMPLE | T-05 | Customer-service chatbot proposed by the contact centre | Built into a service | SUP-013 | Not approved | Public | No | None | None | None | AI-003 | May | Must not | Must not | Must not | None | Not approved: no review | ||
| EXAMPLE | T-06 | Security monitoring service (machine-learning detection) | Built into a service | SUP-006 | Approved | Confidential | Yes | Provider-managed | Contract term | Approve | None | AI-006 | 28 Mar 2027 | May | May | May | Must not | Confidential | In date |
A tool in the state Not approved takes Public information with no personal data in it only (P15 CL-19). No tool takes special category data. Guard the list: only the ai governance lead changes a row (IS-5).
Data Rules
Data rules: states, baseline conditions, supplier terms and reviews
What decides the grid on the Approved Tools sheet. The states, conditions and terms are the pack's, and the AI Acceptable Use & Security Policy holds the rules (AG-02, AG-03, AG-04, AG-11).
The three states of a tool
| State | Meaning |
|---|---|
| Approved | Approved up to the stated data level with the baseline conditions (BC-1 to BC-5) and nothing further. |
| Approved with conditions | Approved up to the stated data level with the baseline conditions and the further conditions listed for the tool. A condition with a date is a condition of the approval, and the tool is switched off if it is not met. |
| Not approved | Not approved for work. Only Public information with no personal data in it may go into it (P15 CL-19), and never through a work account. |
Baseline conditions (BC-1 to BC-5)
| Condition | What it asks | Applies to | Rule |
|---|---|---|---|
| BC-1 | Staff sign in with the work account through single sign-on (P13). No personal or free account. A feature built into a service follows that service's own access rules (P07, P13). | Internal and above | AG-04 (AI Acceptable Use & Security Policy) |
| BC-2 | The contract bars the supplier from training on the organisation's data (ST-1; P15 CL-19). Where the tool also has a setting that stops training, it is kept off and checked at each review as an added technical control; it never replaces the contract term. | Internal and above | AG-03 (AI Acceptable Use & Security Policy) |
| BC-3 | The tool and its supplier are in the inventory (A05) and, for Internal and Confidential data, in the supplier register (P06). | Internal and above | AG-10 (AI Acceptable Use & Security Policy) |
| BC-4 | Confidential data and above only after the supplier's documented decision is Approve or Approve with conditions (P06 TP-05; P15 CL-16). | Confidential and above | AG-11 (AI Acceptable Use & Security Policy) |
| BC-5 | Personal data only where the tool is approved for it, under processor terms (P06 clause CL-06). | Personal data, at any level | AG-03 (AI Acceptable Use & Security Policy) |
What decides each class of data
| Data class | May go into | Baseline conditions | Rule |
|---|---|---|---|
| Public | Public information with no personal data in it may go into any tool (P15 CL-19), never through a work account and never under the organisation's name. Personal data inside it needs a tool approved for personal data (BC-5). | BC-5 if it includes personal data | AG-02 |
| Internal | A tool approved up to Internal or above, in the state Approved or Approved with conditions, with the work account through single sign-on where staff use the tool, and a contract term that bars the supplier from training on our data (BC-2); a setting verified off is an added control, never a substitute. | BC-1, BC-2, BC-3 | AG-03 |
| Confidential | A tool approved up to Confidential or above, in the state Approved or Approved with conditions, with the work account through single sign-on where staff use the tool, and a contract term that bars the supplier from training on our data (BC-2); a setting verified off is an added control, never a substitute. | BC-1, BC-2, BC-3, BC-4 | AG-03 |
| Special category | Special category data never goes into an AI tool (P15 CL-19). | None | AG-03 |
Supplier terms to ask for (ST-1 to ST-8)
| Term | What to ask the supplier | Where it sits | Rule |
|---|---|---|---|
| ST-1 | The supplier does not use our prompts, files or outputs to train or improve its models or anyone else's, and says so in the contract. | No P06 clause: add it as a negotiated term | AG-03 |
| ST-2 | The supplier processes personal data only on our documented instructions. | P06 clause CL-06 | AG-03 |
| ST-3 | The supplier names the sub-processors it uses, including the provider of the underlying model, and gives notice before it changes them. | P06 clause CL-04 | AG-11 |
| ST-4 | The supplier states where prompts, outputs and logs are stored and processed, and gives notice before it changes the locations. | P06 clause CL-05 | AG-11 |
| ST-5 | The supplier notifies us of a security incident that exposes our prompts, outputs, files or accounts. | P06 clause CL-07 | AG-13 |
| ST-6 | On exit the supplier returns and deletes our prompts, outputs, logs, uploaded files and any model or index built from our data. | P06 clause CL-13 | AG-11 |
| ST-7 | The supplier gives notice before it adds or changes an AI feature in a service we already use. | P06 clause CL-20 | AG-09 |
| ST-8 | The supplier gives us in writing the intended purpose and instructions for use of the AI system (EU AI Act Articles 3(12) and 3(15)). | No P06 clause: add it as a negotiated term | AG-07 |
P06 clauses used: CL-04 Sub-processors and subcontracting; CL-05 Locations of service and data; CL-06 Data protection: processor terms; CL-07 Security incident notification; CL-13 Data return and deletion; CL-20 Notice of material changes.
When an approval is reviewed
| Tier of the use | Decided by | Reviewed every |
|---|---|---|
| Tier 1 | AI governance lead | 12 months |
| Tier 2 | AI governance lead and Head of Information Security, with the use owner consulted (the owner signs the conditions it accepts and does not approve) and the Data Protection Officer's advice recorded where personal data is used | 6 months |
| Tier 3 | The executive decision-maker your procedure names (executive management by default; the board or its equivalent where your governance structure puts it), on the AI governance lead's recommendation | 6 months |
| Trigger | A review is forced by | Review started | Rule |
|---|---|---|---|
| Trigger 1 | A new purpose, data level or audience | within [[10]] working days | AG-10 |
| Trigger 2 | A change of supplier, model or location, or a new AI feature | within [[10]] working days | AG-10 |
| Trigger 3 | An incident or near miss involving the use | within [[10]] working days | AG-10 |
| Trigger 4 | A complaint about the output | within [[10]] working days | AG-10 |
| Trigger 5 | A change in law, guidance or the organisation's policy | within [[10]] working days | AG-10 |
| Trigger 6 | A person leaving who was the owner or the checker | within [[10]] working days | AG-10 |
A tool serves several uses. Review it at the shortest interval of the uses that rely on it.
Check a Use
Check a use: may this data go into this tool?
Choose a tool, a class of data and whether it includes personal data. The answer follows the same rules as the grid, and the reason says which rule decided it.
Setting
| As at (reviews are judged against this date) | 30 Sep 2026 |
Ask
| Tool ID (from the Approved Tools sheet) | T-01 |
| Class of data | Internal |
| Does the data include personal data? | No |
The tool as listed (calc)
| Tool | Office suite assistant (writing and summarising) | |
| State | Approved with conditions | |
| Highest data level approved | Internal | |
| Kind | Tool staff use | |
| How people sign in | SSO | |
| How the supplier is barred from training on our data | Contract term | |
| Supplier's decision under P06 | Approve | |
| Approved for personal data? | No | |
| Further conditions | No personal data, customer price lists or other Confidential files. A person reads every output before it is sent or published. Meeting transcription stays switched off until the Data Protection Officer has reviewed it. | |
The answer (calc)
| May this data go into this tool? | May | |
|---|---|---|
| Why | The tool is approved up to Internal. | |
| Baseline conditions that apply | BC-1, BC-2, BC-3 | |
| Further conditions of this tool | No personal data, customer price lists or other Confidential files. A person reads every output before it is sent or published. Meeting transcription stays switched off until the Data Protection Officer has reviewed it. | |
Counts of the list (calc)
| Count | Value | Of the tools on the list |
|---|---|---|
| Tools on the list | 6 | |
| In the state Approved | 1 | of 6 |
| In the state Approved with conditions | 3 | of 6 |
| In the state Not approved | 2 | of 6 |
| That may take Internal data | 3 | of 6 |
| That may take Confidential data | 1 | of 6 |
| That may take personal data | 1 | of 6 |
| With an approval past its review date | 0 | of 6 |
Counts of tools, never a score or a share. Name the tools behind a count when you report it, for example 2 of 6 tools may take Confidential data.
Test Cases
Each row asks the formulas one question and says what the answer should be. Every row must say Agrees. The first 14 rows are the pack's worked cases.
| Row | Tool tested | State | Kind | Highest data level approved | How people sign in | How the supplier is barred from training | Supplier's decision under P06 | Approved for personal data? | Class of data | Personal data in it? | Expected answer | Answer (calc) | Reason (calc) | Check (calc) |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| TEST | Not approved | Not approved | Tool staff use | Public | Personal | None | No | Public | No | May | May | Public information with no personal data in it may go into any tool (P15 CL-19). | Agrees | |
| TEST | Not approved | Not approved | Tool staff use | Public | Personal | None | No | Internal | No | Must not | Must not | The tool is not approved; only Public information may go in. | Agrees | |
| TEST | Approved for Internal | Approved | Tool staff use | Internal | SSO | Contract term | Approve | No | Internal | No | May | May | The tool is approved up to Internal. | Agrees |
| TEST | Approved for Internal | Approved | Tool staff use | Internal | SSO | Contract term | Approve | No | Confidential | No | Must not | Must not | The tool is approved up to Internal, not Confidential. | Agrees |
| TEST | Approved for Internal | Approved | Tool staff use | Internal | SSO | Contract term | Approve | No | Internal | Yes | Must not | Must not | The tool is not approved for personal data (BC-5). | Agrees |
| TEST | Approved for Confidential and personal data | Approved | Tool staff use | Confidential | SSO | Contract term | Approve with conditions | Yes | Confidential | Yes | May | May | The tool is approved up to Confidential. | Agrees |
| TEST | Approved for Confidential and personal data | Approved | Tool staff use | Confidential | SSO | Contract term | Approve with conditions | Yes | Special category | No | Must not | Must not | Special category data never goes into an AI tool (P15 CL-19). | Agrees |
| TEST | Approved for Internal, personal sign-in | Approved with conditions | Tool staff use | Internal | Personal | Contract term | No | Internal | No | Must not | Must not | The baseline needs the work account through single sign-on (BC-1). | Agrees | |
| TEST | Approved for Internal, may train | Approved with conditions | Tool staff use | Internal | SSO | None | No | Internal | No | Must not | Must not | The baseline needs a contract term that bars training on our data; a setting verified off is not enough on its own (BC-2). | Agrees | |
| TEST | Approved for Confidential, no supplier decision | Approved | Tool staff use | Confidential | SSO | Contract term | No | Confidential | No | Must not | Must not | Confidential data needs the supplier's documented decision (BC-4). | Agrees | |
| TEST | Approved for Confidential, setting verified off only | Approved | Tool staff use | Confidential | SSO | Setting verified off | Approve | No | Confidential | No | Must not | Must not | The baseline needs a contract term that bars training on our data; a setting verified off is not enough on its own (BC-2). | Agrees |
| TEST | Approved for Confidential, setting verified off only | Approved | Tool staff use | Confidential | SSO | Setting verified off | Approve | No | Internal | No | Must not | Must not | The baseline needs a contract term that bars training on our data; a setting verified off is not enough on its own (BC-2). | Agrees |
| TEST | Built into a service | Approved | Built into a service | Internal | Local accounts | Contract term | Approve | No | Internal | No | May | May | The tool is approved up to Internal. | Agrees |
| TEST | Not approved | Not approved | Tool staff use | Public | Personal | None | No | Public | Yes | Must not | Must not | Personal data goes only into a tool approved for it. | Agrees |
Lists
| YesNo | ListTraining | ListState | ListLevel | ListDataClass | ListKind | ListSignIn | ListDecision | ListMay |
|---|---|---|---|---|---|---|---|---|
| Yes | Contract term | Approved | Public | Public | Tool staff use | SSO | Approve | May |
| No | Setting verified off | Approved with conditions | Internal | Internal | Built into a service | Local accounts | Approve with conditions | Must not |
| None | Not approved | Confidential | Confidential | Personal | Escalate | |||
| Special category | None | Reject |
Provider-managed
Definitions
Definitions
| Term | Meaning in this workbook |
|---|---|
| Approved tool | An AI tool on the approved list (A07) with a state of Approved or Approved with conditions, and the data levels it may take. |
| Unapproved use | Any use of an AI tool for work that is not on the approved list, or with data above what the list allows. Sometimes called shadow AI. |
| Prompt | What a person types, pastes or uploads into an AI tool. Everything in a prompt counts as data put into the tool. |
| Training on our data | A supplier using what the organisation puts into a tool, or what the tool returns, to train or improve the supplier's models. The approved list records whether the contract or the tool's settings bar it. |
| Work account | The account the organisation gives a person, signed in through single sign-on (P13). A personal or free account is not a work account. |
| State | Where a tool stands on the list: Approved, Approved with conditions, or Not approved. The Data Rules sheet gives the meaning of each. |
| Kind | Tool staff use is a tool people open and sign in to. Built into a service is an AI feature inside software the organisation already runs. A feature built into a service follows that service's own access rules (BC-1). |
| Highest data level approved | The highest of P15's levels (Public, Internal, Confidential) that the approval allows. A tool takes that level and the levels below it, if the baseline conditions are met. |
| May | The data may go into the tool, on the conditions shown. The answer follows the rules; it does not replace the intake decision. |
| Must not | The data must not go into the tool. The reason says which rule decided it. |
| BC-1 to BC-5 | The baseline conditions of every approved tool, on the Data Rules sheet. |
| ST-1 to ST-8 | The supplier terms to ask for, on the Data Rules sheet. |
| (calc) | A column or cell the workbook calculates. Do not type or paste over it. |
| EXAMPLE | A worked example: a wholesale distributor with about 900 staff, three warehouses and an online ordering service that takes 60% of its orders, Q3 2026. Delete before approval. |
| TEST | A row on the Test Cases sheet that asks the formulas one question. It is not part of the example. Delete before approval, keeping any test you added. |
Framework References
Framework references
These references indicate relevance only and do not reproduce the text of any standard.
| Framework | Reference | Supported by |
|---|---|---|
| ISO/IEC 27001:2022 | Annex A 5.10 — Acceptable use of information and other associated assets | Approved Tools and Data Rules: the rules for the acceptable use of information and other assets when an AI tool is used |
| ISO/IEC 27001:2022 | Annex A 5.12 — Classification of information | Data class and highest level columns: information classified by P15's levels decides what each tool may take |
| NIST CSF 2.0 | PR.DS-10 — “The confidentiality, integrity, and availability of data-in-use are protected” | Approved Tools and Check a Use: data kept from the wrong tool, in use as well as in storage |
| ISO/IEC 42001:2023 | Annex A 9.2 — Processes for responsible use of AI systems | Approved Tools, Data Rules and Check a Use: the processes for the responsible use of AI systems |
| ISO/IEC 42001:2023 | Annex A 10.3 — Suppliers | Supplier terms ST-1 to ST-8 and the supplier decision column: what the organisation asks of the suppliers of AI systems |
| EU AI Act — Regulation (EU) 2024/1689 | Article 3(12) — “intended purpose” means “the use for which an AI system is intended by the provider, including the specific context and conditions of use, as specified in the information supplied by the provider in the instructions for use, promotional or sales materials and statements, as well as in the technical documentation” | Further conditions: a tool is approved for the purpose the supplier gives, and ST-8 asks for it in writing |
| EU AI Act — Regulation (EU) 2024/1689 | Article 50(2) — providers of AI systems, including general-purpose AI systems, generating synthetic audio, image, video or text content “shall ensure that the outputs of the AI system are marked in a machine-readable format and detectable as artificially generated or manipulated”; providers of systems placed on the market before 2 August 2026 have until 2 December 2026 to take the necessary steps (Article 111(4), added by Regulation (EU) 2026/1744) | Design tool image generator row: the supplier marks generated images, and the organisation does not remove the mark |
| EU AI Act — Regulation (EU) 2024/1689 | Article 113, as amended — the Regulation applies from 2 August 2026, except that Chapters I and II (including Articles 4 and 5) apply from 2 February 2025, with Article 5(1) points (ba) and (bb) and Article 5(1a) and (1b) applying from 2 December 2026; Chapter III Section 4, Chapter V (general-purpose AI models), Chapter VII and Chapter XII and Article 78 apply from 2 August 2025, except Article 101; and Chapter III Sections 1, 2 and 3, except Article 6(5), apply from 2 December 2027 as regards systems classified as high-risk under Article 6(2) and Annex III, and from 2 August 2028 as regards those under Article 6(1) and Annex I. Article 50 is not listed in an exception and so applies from 2 August 2026 | Dates the Act applies, as the pack states them; no column of this workbook depends on a date in the Act |
| EU AI Act — Regulation (EU) 2026/1744 (Digital Omnibus on AI) | Regulation (EU) 2026/1744 of 8 July 2026 amending Regulations (EU) 2024/1689, (EU) 2018/1139 and (EU) 2023/1230 as regards the simplification of the implementation of harmonised rules on artificial intelligence (Official Journal, 24 July 2026); in force on the third day after publication (its Article 4), 27 July 2026. Its Article 1 amends Regulation (EU) 2024/1689 | The text of the Act as amended, on which the pack's references rest |
| NIST AI RMF 1.0 | GOVERN 6.1 — “Policies and procedures are in place that address AI risks associated with third-party entities, including risks of infringement of a third-party’s intellectual property or other rights.” | Supplier terms (ST-1 to ST-8) and the supplier decision column: policies for risks from third-party software and data |
| NIST AI RMF 1.0 | MAP 4.1 — “Approaches for mapping AI technology and legal risks of its components – including the use of third-party data or software – are in place, followed, and documented, as are risks of infringement of a third party’s intellectual property or other rights.” | Approved Tools and the supplier terms: legal risks of third-party components and tools mapped |
| NIST AI RMF 1.0 | MEASURE 2.7 — “AI system security and resilience – as identified in the MAP function – are evaluated and documented.” | Sign-in, training bar and review columns: the security and resilience of the system as evaluated |
| GDPR — Regulation (EU) 2016/679 | Article 5(1)(c) — personal data shall be “adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’)” | Highest data level approved: only the data the purpose needs goes into a tool |
| GDPR — Regulation (EU) 2016/679 | Article 5(1)(f) — personal data shall be “processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’)” | Baseline conditions BC-1 to BC-4: data processed securely, with a work account and a supplier decision |
| GDPR — Regulation (EU) 2016/679 | Article 9(1) — “Processing of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation shall be prohibited.”, unless one of the conditions of Article 9(2) applies | Special category column: no tool takes special category personal data |
| GDPR — Regulation (EU) 2016/679 | Article 28(1) — use only processors providing sufficient guarantees of appropriate technical and organisational measures | Supplier decision column and ST-2: a processor with sufficient guarantees |
| GDPR — Regulation (EU) 2016/679 | Article 28(3) — a binding contract with the processor, covering documented instructions, confidentiality, security, sub-processors, assistance, return or deletion of data, and audits | ST-2 to ST-6 and BC-5: the contract terms a processor of personal data is held to |
| GDPR — Regulation (EU) 2016/679 | Article 32(1) — appropriate technical and organisational measures to ensure a level of security appropriate to the risk, taking into account the likelihood and severity of risk to people's rights and freedoms | Baseline conditions and further conditions: technical and organisational measures for the data in the tool |
| NIS2 — Directive (EU) 2022/2555 | Article 21(2)(d) — “supply chain security, including security-related aspects concerning the relationships between each entity and its direct suppliers or service providers” | Supplier terms and review dates: supply chain security, including the relationship with each supplier |
| NIST AI 600-1 | NIST AI 600-1, Artificial Intelligence Risk Management Framework: Generative Artificial Intelligence Profile, July 2024, cited by number and title | Approved Tools and further conditions: risks specific to generative AI that the conditions address |
Editions referenced: Regulation (EU) 2024/1689 (the EU AI Act) as amended by Regulation (EU) 2026/1744; ISO/IEC 27001:2022 incl. Amd 1:2024; ISO/IEC 42001:2023 (by number and title only); NIST CSF 2.0; NIST AI RMF 1.0; Regulation (EU) 2016/679 (GDPR); as published and read on 8 October 2026
ISO/IEC 27001 and ISO/IEC 42001 references name the clause or control this document relates to, by number and title only. ISO/IEC 42001 is a paid standard whose text was not read for this document. A reference does not say that meeting a clause or control meets any requirement of the EU AI Act.
This pack does not say which ISO/IEC 42001 or ISO/IEC 27001 controls, or which NIST AI RMF outcomes, meet a requirement of the EU AI Act. Each reference says what the source asks for and which CISO Times document helps with that work. Using a document does not by itself show that a requirement is met.