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The CISO Decision Brief

AI Use Case Risk & Impact Assessment

Assesses security, privacy, fairness and operational impact of an AI use case before approval.

Available soon

Format
Excel
Size
76 KB
Length
12 sheets
Version
1.1
Updated

What's inside

What changed

  1. 1.1

    Hold H-2 applies to Internal data as well as Confidential: either goes in only under a contract term that bars the supplier from training on it, and a setting verified off does not clear the hold.

  2. 1.0

    Published.

Changes across this pack

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

StepWhat to do
1Do this first: take the proposed use through intake (AI Use Case Intake & Approval Procedure) and keep its answers. Tier 2 and Tier 3 uses need this assessment (IS-3). Tier 1 uses need only the screen.
2On the Use sheet, enter the intake answers (IQ-04 to IQ-12) and the supplier terms. Answer IQ-12 Yes when the use is built on a supplier's model API, for staff or for customers; that is a signal for Legal and not a finding. Enter the role Legal records in the role cell, and H-4 clears. The sheet works out the tier from the answers, as the procedure does, and names the holds. A prohibited practice or special category data stops the use here (AG-05, AG-03).
3On the Result sheet, enter the date of this assessment, who assessed it and your appetite for AI-use risk (Cautious is the house default).
4On the Factors sheet, rate each of the 6 factors twice. First rate the risk as it stands before any control: impact 1 to 4 and likelihood 1 to 4. Read the words for each impact level on the Scales sheet. Then name the controls that lower it, who checks them, and rate the risk again. A control can lower a rating and never raise it.
5Apply the safety rule: Where the output or action could physically harm a person, rate the impact 4 (Severe) whatever the other areas say. The use is Tier 3 and Legal is told.
6Read the Result sheet: the count of factors in each band after controls, the highest band, the factors outside appetite or tolerance and who may accept them, the lowest tier the assessment allows, and the tier for the decision. If the assessment raises the tier, take the use to the approvers of the higher tier.
7On the Decision sheet, record the decision (Approved, Approved with conditions, Held, Declined), who decided, the date and the reason. Clear or keep each hold. Attach the baseline conditions and add any further conditions with a person to check each and a date.
8Enter the outcome in the AI System & Use Case Inventory (status, tier, approver, review date) and update the AI Tool Approval & Data Permission Matrix. Keep this workbook with the intake file for the period in AG-12.

Legend

Yellow cells are inputs. Everything else is calculated or fixed — do not overwrite formulas.

EXAMPLERows marked EXAMPLE in the first column show how a completed row looks. Delete them before approval.

Limitations: 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.

What this workbook does not do. This worksheet records your own reasoning against the text of the Act. It does not say that any system is or is not prohibited, high-risk or subject to a transparency duty, and it does not say that you are a provider, a deployer or any other operator. Counsel confirms each conclusion.

The idea behind it. Most organisations do not build AI. They use other people's AI: an assistant inside the office suite, a forecasting feature in a system they already run, a chatbot a supplier offers, or a free tool a member of staff finds on their own. Governing that use proportionately starts with knowing what is in use. For each use, the organisation then decides what data it may touch, who answers for it and how much checking it needs. A small use with low-risk data needs a short screen and a named owner. A use that touches Confidential data, faces customers, acts on its own or helps decide something about a person needs an assessment and a senior decision first. A few uses are never allowed. The result is a list the organisation keeps, with counts of what is approved, held, declined and due for review. It is never one score.

Counts, not a score. The result is the number of factors in each band after controls, the highest band and the tier (AG-22). The workbook never adds the factors together.

The rules this workbook applies: AG-03, AG-05, AG-06 ("No AI output decides, alone, a matter that affects a person's job, pay, discipline, credit, access to a service or legal position (GDPR Article 22). A named person makes the decision after reading the evidence. A use that decides or shapes such a decision, or that falls in an area of Annex III of the EU AI Act whatever it does, is Tier 3 and is not started before the Tier 3 decision. A use that only informs such a decision is Tier 2."), AG-09, AG-10, AG-11, AG-12, AG-16 and AG-17. The other rules are in the AI Acceptable Use & Security Policy.

EXAMPLE: A customer-service chatbot, proposed by the outsourced contact centre, that answers order-status questions, proposed by the Chief Operating Officer of the distributor on 9 Sep 2026. The workbook shows its assessment of 23 Sep 2026 and the decision of the Executive Committee on 29 Sep 2026: held. The distributor has about 900 staff and is an important entity under NIS2 in its Member State.

Adapting this template

Small organisation: one person can fill in the Use and Factors sheets in an hour for a Tier 2 use. Keep the evidence short and name one person who checks each control. Tier 3 still goes to the executive decision-maker the procedure names.

Regulated organisation: if a sector regulator or a customer contract sets extra duties for automated decisions or outsourcing, add them as further conditions on the Decision sheet and as questions you ask under RF-6.

Service provider or outsourced IT: rate a factor on what you can show, not on what the provider says. The AI use owner is the person who manages the provider, and the supplier terms ST-1 to ST-8 go into the contract before approval.

Amounts and appetite: replace the amounts in double brackets on the Scales sheet with the ones in your risk assessment methodology (P05), and change the appetite on the Result sheet if your leadership team has set a different one.

This workbook is your own record. Keep it with the evidence it rests on.

Use

The use and the intake answers

Describe the use and give the intake answers (AI Use Case Intake & Approval Procedure, IQ-01 to IQ-12). The tier follows from the answers. Yellow cells are yours; the rest calculates (AG-06, AG-09).

FieldYour answerHelp

The use

Use ID (A05)AI-003The ID the use has in the AI System & Use Case Inventory (A05).
IQ-01 The useA customer-service chatbot, proposed by the outsourced contact centre, that answers order-status questionsWhat is the use, in one sentence, and what does the business gain?
IQ-02 Tool or featureCustomer-service chatbotWhich tool or feature, from which supplier (the P06 reference, or none)? Is it already running? What do the supplier's assessment, contract and processor terms say?
IQ-02 Supplier (P06 reference, or blank)SUP-013Leave blank if there is no supplier record. A supplier here means the supplier terms below can create a hold.
IQ-03 AI use ownerChief Operating OfficerWhich manager is the AI use owner, and who reads the output before it is used?
IQ-03 Who reads the output before it is usedCustomer service team leader, who reviews a sample of conversations each weekThe person with the authority to reject the output (AG-07).
Already running?NoYes if the use is already running, for example found in the inventory survey. A hold then becomes a condition with a date.

What goes in, who sees it and what it affects

IQ-04 Highest data levelConfidentialWhat is the highest level of information that goes in (P15)?
IQ-05 Special category dataNoCould special category personal data go in (health, trade union membership, biometric data and the others of GDPR Article 9)?
IQ-06 Personal dataYesCould any personal data go in or come out?
IQ-07 AudienceCustomers or the public deal with the system or see its output directlyDo customers or the public deal with the system, or see its output directly, or does a person review anything that leaves the organisation?
IQ-08 AutonomyIt acts, or sends output, without a person reading it firstDoes a person read every output before it is used, or does the system act or send output on its own?
IQ-09 Effect on peopleNoneDoes the use inform a decision about a person, or decide or shape one (recruitment, pay, performance, discipline, credit, access to a service)? A use that decides or shapes one is Tier 3; a use that only informs one is Tier 2.
IQ-10 Operational effectLowIf the output were wrong or the tool stopped, would a core service or a material sum be affected (more than P05's Minor level in any impact area)?
IQ-11 Possible prohibited practiceNoYes if any item on the prohibited-practice checklist (A08, PP-01 to PP-10) is Yes or Unsure.
IQ-11 Annex III area tickedNoYes if the use might fall in an area of Annex III (A08, HA-1 to HA-8). Legal confirms; the workbook only routes the request.
IQ-12 Provider signalNoWould the organisation build an application or feature on a supplier's model API (prompts, retrieval, tools or code around a model it calls), whether for staff or for customers, fine-tune for others, brand, sell or supply the system, or change what it is meant for? Using a supplier's finished product as supplied is not building. Is it already running?
IQ-12 Role Legal recorded (A08), or blankLeave blank until Legal records the role (Deployer, Provider or Other) with its reasoning in the A08 row. A Yes to IQ-12 holds a new use at H-4 and sets Tier 3 until a role is entered. Deployer: the tier is then worked out again from the other answers. Provider or Other: the hold clears but the use stays Tier 3, because it is outside the deployer governance of this pack (a use already running carries H-4 as a condition with a date).

Supplier terms (they decide the holds)

Supplier's decision under P06None yetThe supplier's decision under the third-party pack (P06). Choose None yet if there is none.
How training on our data is barredNoneContract term if the contract bars the supplier from training on our data (ST-1). Setting verified off if only a vendor setting does: not enough for Internal or Confidential data, because the supplier can change it (BC-2, H-2). None if neither does. Where there is a contract term, keep any such setting off too.
Processor terms signedNoYes if processor terms are signed (P06 clause CL-06).
Answers complete (working)Yes
Stop (working)No

What sets the tier (A03, IS-2)

TriggerWhat it meansApplies?TierRule
IQ-11 A prohibited practice may matchThe use may match a prohibited practice. It is not started, and Legal is told.NoStopAG-05
IQ-05 Special category data could go inSpecial category personal data would go into an AI tool. It never does (P15 CL-19). Change the use so that it does not.NoStopAG-03
IQ-11 An Annex III area is tickedThe use falls in an area of Annex III of the EU AI Act. It is Tier 3.No3AG-06
IQ-09 Decides or shapes a decision about a personThe use decides or shapes a decision about a person (GDPR Article 22; Annex III).No3AG-06
IQ-08 Acts or sends output without a person reading itThe system acts or sends output without a person reading it first.Yes3AG-16
IQ-12 A provider signal with no role recorded by Legal, and not yet runningBuilding on a supplier's model API counts as building. That is a signal, not a classification, and Legal records the role (D-51). A new use is Tier 3 until Legal has recorded it.No3AG-17
IQ-12 Legal recorded the Provider or Other role: H-4 clears, the use stays Tier 3Legal recorded a role other than deployer (provider or other). The use is outside this pack's deployer governance, so it stays Tier 3: the executive decision-maker decides, with the EU AI Act worksheet (A08) confirmed by Legal.No3AG-17
IQ-04 Confidential information goes inConfidential information would go in.Yes2AG-03
IQ-06 Personal data goes in or comes outPersonal data would go in or come out.Yes2AG-03
IQ-07 Customers or the public deal with itCustomers or the public deal with the system or see its output.Yes2AG-08
IQ-09 Informs a decision about a personThe use informs a decision about a person.No2AG-06
IQ-10 A wrong output or a stoppage would be materialA wrong output or a stoppage would affect a core service or a material sum.No2AG-10
None of the abovePublic or Internal non-personal data, staff only, a person reads every output, no effect on a person, and a low operational effect.No1AG-09
Tier from the intake answers3Tier 3: assessment and executive decision. The assessment may raise it (Result sheet).
The workbook routes the request as AI Use Case Intake & Approval Procedure does. It does not say that a use is prohibited, high-risk or subject to a transparency duty. This worksheet records your own reasoning against the text of the Act. It does not say that any system is or is not prohibited, high-risk or subject to a transparency duty, and it does not say that you are a provider, a deployer or any other operator. Counsel confirms each conclusion.

Factors

One row per factor. Rate the risk before controls, name the controls, then rate it again. Yellow columns are yours; the columns to the right of the second likelihood calculate. EXAMPLE: AI-003, a customer-service chatbot, proposed by the outsourced contact centre, that answers order-status questions.

ExampleFactor IDFactorWhat to askP05 impact areasEvidence to look atImpact before controls (1 to 4)Likelihood before controls (1 to 4)Controls that lower it, and who checks themImpact after controls (1 to 4)Likelihood after controls (1 to 4)What the impact after controls means (P05)Band before controlsBand after controlsAgainst appetiteWho may accept itCheckValid (working)Band rank (working)Outside appetite so far (working)Outside tolerance so far (working)
EXAMPLERF-1SecurityCould the use expose the organisation's data or systems, or be turned against them: leaked prompts or files, prompt injection, an insecure plug-in, stolen credentials, malicious output?Data, ServiceThe tool's settings, sign-in, logging and data location; the supplier's security assurance; the access the system holds.33Read-only lookup of order status; no write access; prompt injection testing before go-live.32Data: personal or customer data of [[hundreds]] of people, or commercially sensitive data; Service: a core customer service stopped for up to [[2]] daysHighMediumWithin appetiteRisk owner and Head of Information SecurityOK12
EXAMPLERF-2PrivacyDoes personal data go in or come out? Is there a lawful basis, a purpose limit, processor terms, and a need for a data protection impact assessment (GDPR Article 35)?Data, Legal and regulatoryWhat personal data, whose, how much; the Data Protection Officer's advice; the processor terms; the retention of prompts and outputs.33Customer personal data at scale. No reduction until processor terms and the Data Protection Officer's advice are in place (H-3).33Data: personal or customer data of [[hundreds]] of people, or commercially sensitive data; Legal and regulatory: a formal enquiry by a regulator or customer, or a contract breach with penaltiesHighHighOutside appetite, within toleranceAccountable executive and Head of Information Security, and executive management as wellOK13RF-2
EXAMPLERF-3FairnessCould the output treat people unfairly or unequally, or carry bias into a decision, a message or a published item?Legal and regulatory, ReputationWho is affected; what the output is used for; how a person checks it; how a person can challenge it.22Same answers to every customer; a person takes over on request; weekly review of a sample.21Legal and regulatory: a minor breach of contract or policy, put right without penalty; Reputation: noticed by some customers or suppliersMediumLowWithin appetiteRisk ownerOK11RF-2
EXAMPLERF-4SafetyCould the output or the action physically harm a person or damage property?Service, FinancialThe physical processes the output can reach, and the checks between the output and the action.11Order status only.11Service: an internal service degraded for hours; Financial: less than [[€50,000]]LowLowWithin appetiteRisk ownerOK11RF-2
EXAMPLERF-5OperationalWhat happens if the output is wrong, the tool is unavailable or the supplier withdraws it? Can the business carry on, and is there a way back?Service, FinancialThe process it supports, the manual fallback, the exit route (P06 TP-11) and who notices a wrong output.23Agents take over; the contact centre can switch it off the same day.22Service: a customer service degraded, or an internal service stopped, for up to [[1]] day; Financial: [[€50,000]] to [[€250,000]]MediumMediumWithin appetiteRisk owner and Head of Information SecurityOK12RF-2
EXAMPLERF-6Legal and contractualDoes the use fit the law, the organisation's contracts, customers' terms, intellectual property and the worksheet's reading of the EU AI Act (A08)?Legal and regulatory, ReputationThe contract terms, the confidentiality duties, the A08 reasoning and Legal's confirmation.33Article 50(1) notice in the first message; ST-1 to ST-8 in the contract; Legal's reading (A08).32Legal and regulatory: a formal enquiry by a regulator or customer, or a contract breach with penalties; Reputation: complaints from several major customers, or regional or trade pressHighMediumWithin appetiteRisk owner and Head of Information SecurityOK12RF-2

The safety rule. Where the output or action could physically harm a person, rate the impact 4 (Severe) whatever the other areas say. The use is Tier 3 and Legal is told.

Judge impact on the scales on the Scales sheet, never on a second scale. A factor can be Low and still carry a condition. Add a factor on a new sheet if the use raises a risk none of these six covers, and say so in the decision reason.

Result

Result

Counts of factors by band after controls, the highest band, the lowest tier the assessment allows and the tier for the decision, calculated from the Factors and Use sheets. Only the yellow settings are yours. Every figure is a count or a tier (AG-22).

EXAMPLE: AI-003, a customer-service chatbot, proposed by the outsourced contact centre, that answers order-status questions. Clear the EXAMPLE column and the yellow answers to use your own.

Settings

Date of this assessment23 Sep 2026EXAMPLE: the date the assessment was done.
Assessed by (role)EXAMPLE: Head of Information SecurityThe person who rated the factors and checked the evidence (A03, IS-3).
Appetite for AI-use riskCautiousCautious is the house default. Averse, Cautious or Open (P05). Set it with your leadership team.
Appetite and tolerance (working)MediumHighAppetite band, then tolerance band.

Factors by band

BandAfter controlsBefore controlsScoresWhat the band means for acceptance (P05)
Low211–3Risk owner; review every 12 months
Medium324–6Risk owner and Head of Information Security; review every 12 months
High138–9Accountable executive and Head of Information Security; review every 6 months
Critical0012–16The board, or a board risk committee it has delegated this to; in a two-tier structure, the management board; where there is no board, such as in an owner-managed company, executive management; review every 3 months
Factors rated666 of 6

The assessment in numbers

In one line6 of 6 factors rated; 2 Low, 3 Medium, 1 High, 0 Critical after controls
Highest band after controlsHigh
Safety rule applies?NoWhere the output or action could physically harm a person, rate the impact 4 (Severe) whatever the other areas say. The use is Tier 3 and Legal is told.
Lowest tier the assessment allows2The lowest tier the assessment allows: Tier 2 when the highest band after controls is High, Tier 3 when it is Critical or the safety rule applies, otherwise Tier 1. The tier for the decision is the higher of the intake tier and this floor.
Factors outside appetiteRF-2These need a higher approver than the band alone sets; see the Factors sheet (P05).
Factors outside toleranceNoneOnly the board or its equivalent may accept a factor outside tolerance (P05).

Tier and who decides

Tier from the intake answers3
Lowest tier the assessment allows2
Tier for the decision3
In one lineTier 3: assessment and executive decision: the assessment does not raise the tier.
Assessment needed at this tier?Yes
Who decidesThe 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
What the tier needsEverything in Tier 2, the EU AI Act worksheet (A08) confirmed by Legal, a data protection impact assessment where Article 35 of the GDPR applies, and HR where staff are affected.
Working days to decide, from a complete file30
Months between reviews of an approval6

Limitations

This assessment is as good as the evidence behind each rating. Look at the tool's settings, the contract and the records. Do not rely on what a supplier or a colleague says.

The ratings are judgement on a four-point scale. A second person who reads the factors and the controls is the best defence against optimism.

The impact thresholds in the Scales sheet come from your risk assessment methodology (P05). Replace the amounts in double brackets with yours so the two documents agree.

The workbook routes a use to the right tier and decision. It does not say that a system is or is not in a category of the EU AI Act, or that you are a provider or a deployer. Legal confirms those readings (A08).

The result is counts of factors by band and a tier. Never turn the counts into a percentage, a score or a traffic-light total.

Decision

The decision and its conditions

Record the decision, clear or keep each hold, and attach the baseline conditions. The tier decides who may decide (AI Use Case Intake & Approval Procedure, IS-4). Any approver may hold or decline. Only the approvers of the tier may approve, and the executive decision-maker takes the place of an approver who owns the use.

EXAMPLE: AI-003, held on 2026-09-29. Clear the EXAMPLE values and the yellow answers to use your own.

The decision

Date the file was complete23 Sep 2026The day the intake answers, the assessment and the supplier decision (if needed) were all in. The tier's days count from it.
DecisionHeldChoose from the list. This becomes the status in the AI System & Use Case Inventory.
Decided by (role)Executive CommitteeThe approvers of the tier (never the use owner; the executive decision-maker takes the place of an approver who owns the use). The executive decision-maker the procedure names decides Tier 3.
Decided on29 Sep 2026The date of the decision.
ReasonExecutive Committee, 29 Sep 2026: held until the contact centre's assessment under P06 (planned 1 Dec 2026), a bar on training on our data and processor terms for the chatbot are in place, and the Data Protection Officer has advised on a data protection impact assessment.Say why, in a sentence or two. For a hold, say what clears it.
Hold to be reviewed by (if Held)1 Dec 2026EXAMPLE: the date of the supplier's assessment under P06. Leave blank for any other decision.
Decision due by4 Nov 2026The tier's working days after the file is complete.
Decided in time?Yes
Review the approval byOnly for an approval. Review sooner on a trigger (AG-10, IS-7).
Holds to clear before it startsH-1, H-2, H-3
Baseline conditions that apply5 of 5
CheckOK

Holds a new use must clear first (A03)

HoldClears whenApplies?StatusRule
H-1 The use has a supplier with no documented decision under the third-party pack yet, and either Internal or Confidential data would go in or the use is Tier 2 or 3 even with Public data (P06 TP-01, TP-05; P15 CL-16 asks for it for Confidential data only, and this procedure asks earlier). A use with no supplier raises no H-1: there is nothing to assess.The supplier's assessment ends in Approve or Approve with conditions.YesHoldAG-11
H-2 Internal or Confidential data would go in, and the contract does not carry a term barring the supplier from training on it (ST-1; P15 CL-19). A setting verified off does not clear it: the supplier can change a setting, and only the contract binds it.The contract carries the term barring training on the organisation's data.YesHoldAG-03
H-3 Personal data would go in, and there are no processor terms (P06 clause CL-06).Processor terms are signed, and the Data Protection Officer's advice is recorded.YesHoldAG-03
H-4 A provider signal is present: the organisation would build on a supplier's model API, brand, supply or change the purpose of the system (AG-17). The signal is not a classification.Legal records which role the organisation holds (deployer, provider or other), with its reasoning in A08. If the role is deployer, the tier is set again from the answers. If it is provider or other, the hold clears but the use stays Tier 3: the executive decision-maker decides, with A08 confirmed by Legal.NoAG-17
A use already running does not wait: each hold that applies becomes a condition with a date, and the tool is switched off if it is not met. The supplier's decision comes from the third-party pack (P06).

Baseline conditions that go with every approval (BC-1 to BC-5)

ConditionWhyApplies?From data levelRule
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 or higher goes in.YesInternalAG-04
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 or higher goes in.YesInternalAG-03
BC-3 The tool and its supplier are in the inventory (A05) and, for Internal and Confidential data, in the supplier register (P06).Internal or higher goes in.YesInternalAG-10
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 or higher goes in.YesConfidentialAG-11
BC-5 Personal data only where the tool is approved for it, under processor terms (P06 clause CL-06).Personal data goes in or comes out.YesPublicAG-03

Further conditions of this approval

ConditionWho checks itBy when
[[A further condition, if any: what must be true]][[Role]][[YYYY-MM-DD]]

A condition with a date is a condition of the approval, and the tool is switched off if it is not met. Record each one in the AI Tool Approval & Data Permission Matrix against the tool.

Scales

The scales behind the ratings

The impact and likelihood scales and the bands are the ones in your risk assessment methodology (P05). The AI factors are rated on them and on no other scale. Replace the amounts in double brackets with yours.

Impact: the words for each level, by area

Area1 Minor2 Moderate3 Major4 Severe
Financialless than [[€50,000]][[€50,000]] to [[€250,000]][[€250,000]] to [[€1,000,000]]more than [[€1,000,000]]
Servicean internal service degraded for hoursa customer service degraded, or an internal service stopped, for up to [[1]] daya core customer service stopped for up to [[2]] daysa core customer service stopped for more than [[2]] days
Datainternal, non-personal datainternal confidential data, or personal data of a few peoplepersonal or customer data of [[hundreds]] of people, or commercially sensitive datapersonal or customer data at scale
Legal and regulatoryno notification or breacha minor breach of contract or policy, put right without penaltya formal enquiry by a regulator or customer, or a contract breach with penaltiesa notifiable breach, enforcement or contract termination
Reputationnot noticed outside the teamnoticed by some customers or supplierscomplaints from several major customers, or regional or trade pressnational press, or loss of a major customer

Each factor is judged in the areas named for it: RF-1: Data and Service; RF-2: Data and Legal and regulatory; RF-3: Legal and regulatory and Reputation; RF-4: Service and Financial; RF-5: Service and Financial; RF-6: Legal and regulatory and Reputation. Judge the worse of the areas.

Likelihood

LevelNameMeaning
1UnlikelyNot reachable from the internet or by ordinary users; no known exploitation; strong compensating control in place.
2PossibleReachable internally; exploitation needs skill or insider access.
3LikelyReachable by many users or from partner networks; exploitation techniques are public.
4Almost certainInternet-facing or known to be actively exploited, with no effective compensating control.

Impact times likelihood gives the band

Impact \ Likelihood1 Unlikely2 Possible3 Likely4 Almost certain
1 MinorLow (1)Low (2)Low (3)Medium (4)
2 ModerateLow (2)Medium (4)Medium (6)High (8)
3 MajorLow (3)Medium (6)High (9)Critical (12)
4 SevereMedium (4)High (8)Critical (12)Critical (16)

The product finds the band for one factor. Products are never added across factors.

Appetite and tolerance

AppetiteAccepted without escalation up toTolerated, with a plan, up toMeaning
AverseLowMediumWe avoid this risk and act on anything above Low.
CautiousMediumHighWe accept some risk for a clear business benefit, with controls.
OpenHighHighWe accept higher risk to pursue opportunity; Critical is never within tolerance.

The highest band accepted without escalation. Tolerance is the highest band tolerated while a plan brings it back (P05). Critical is never within tolerance.

Lists

Rating14YesNoRoleChoiceTrainingBarDataLevelAudienceChoiceAutonomyChoicePeopleChoiceOpsChoiceSupplierDecisionOutcomeChoiceAppetiteNameAppetiteBandToleranceBandBandNameBandMinAuthKeyAuthTextTierNameTierAssessTierDecideTierNeedsTierDaysTierMonths
1YesDeployerContract termPublicStaff only: a person reviews anything that leaves the organisationA person reads every output before it is usedNoneLowNone yetApprovedAverseLowMediumLow1Low|Within appetiteRisk ownerTier 1: screenNoAI governance leadA screen against the intake questions. No assessment.512
2NoProviderSetting verified offInternalCustomers or the public deal with the system or see its output directlyIt acts, or sends output, without a person reading it firstInforms a decision about a personMaterialApproveApproved with conditionsCautiousMediumHighMedium4Low|Outside appetite, within toleranceRisk owner, and executive management as wellTier 2: assessmentYesAI 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 usedThe risk and impact assessment (A06), the supplier decision under P06 where a supplier is involved, and the Data Protection Officer's advice where personal data is used.156
3OtherNoneConfidentialDecides or shapes a decision about a personApprove with conditionsHeldOpenHighHighHigh8Low|Outside toleranceRisk owner recommend; only the board or its equivalent may acceptTier 3: assessment and executive decisionYesThe 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 recommendationEverything in Tier 2, the EU AI Act worksheet (A08) confirmed by Legal, a data protection impact assessment where Article 35 of the GDPR applies, and HR where staff are affected.306
4EscalateDeclinedCritical12Medium|Within appetiteRisk owner and Head of Information Security
RejectMedium|Outside appetite, within toleranceRisk owner and Head of Information Security, and executive management as well
Medium|Outside toleranceRisk owner and Head of Information Security recommend; only the board or its equivalent may accept
High|Within appetiteAccountable executive and Head of Information Security
High|Outside appetite, within toleranceAccountable executive and Head of Information Security, and executive management as well
High|Outside toleranceAccountable executive and Head of Information Security recommend; only the board or its equivalent may accept
Critical|Outside toleranceThe band's approvers recommend; only the board or its equivalent may accept

Definitions

Definitions

TermMeaning in this workbook
AI useOne way the organisation uses an AI system, for one purpose, with one owner: summarising meeting notes with the office assistant, or forecasting stock with the warehouse system. One tool can have several uses. The inventory lists uses.
TierHow much checking a proposed use needs before it starts: Tier 1 a screen, Tier 2 an assessment, Tier 3 an assessment and an executive decision. A fourth outcome, Stop, means the use is not allowed.
Human oversightA named person who is competent to judge the output reads it before it is relied on, sent outside the organisation or published, and has the authority to reject it.
Training on our dataA 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.
Before controlsThe rating of a factor before any control: an impact and a likelihood, each from 1 to 4, on the risk assessment scales (P05). Judge it as if nothing you plan were in place.
After controlsThe rating of a factor after the controls named beside it. A control can lower a rating and never raise it. The band after controls is the one that counts.
BandThe band an impact multiplied by a likelihood falls in: Low, Medium, High or Critical (P05). The product only finds the band. It is never added to another factor's product, and the workbook gives no total.
Against appetiteWhere a factor's band after controls sits against the appetite for AI-use risk: within appetite, outside appetite but within tolerance, or outside tolerance (P05).
Appetite and toleranceThe highest band accepted without escalation. Tolerance is the highest band tolerated while a plan brings it back (P05). Critical is never within tolerance.
Lowest tier the assessment allowsThe lowest tier the assessment allows: Tier 2 when the highest band after controls is High, Tier 3 when it is Critical or the safety rule applies, otherwise Tier 1. The tier for the decision is the higher of the intake tier and this floor.
HoldA condition a new use must clear before it starts (H-1 to H-4). A use already running gets a condition with a date instead.
Baseline conditionA condition that goes with every approval, from the data level shown (BC-1 to BC-5). A tool approved with conditions carries them as well.
Safety ruleWhere the output or action could physically harm a person, rate the impact 4 (Severe) whatever the other areas say. The use is Tier 3 and Legal is told.
RF-1 to RF-6, IQ-01 to IQ-12The six risk factors of this workbook and the twelve intake questions of the AI Use Case Intake & Approval Procedure.
AG-xx, IS-x, H-x, BC-xA rule of the AI Acceptable Use & Security Policy, a stage of the AI Use Case Intake & Approval Procedure, a hold and a baseline condition.
EXAMPLEA worked example: AI-003, as at 30 Sep 2026. Clear the EXAMPLE values and the yellow answers before use.

Framework References

Framework references

These references indicate relevance only and do not reproduce the text of any standard.

FrameworkReferenceSupported by
ISO/IEC 27001:2022Clause 6.1.2 — Information security risk assessmentThe workbook as a whole: a risk assessment of one AI use, with its results recorded
NIST CSF 2.0ID.RA-04 — “Potential impacts and likelihoods of threats exploiting vulnerabilities are identified and recorded”Factors and Result sheets: the impacts and likelihoods of the use are identified and recorded
ISO/IEC 42001:2023Clause 6.1.2 — AI risk assessmentFactors and Result sheets: the risk assessment of one use
ISO/IEC 42001:2023Clause 6.1.3 — AI risk treatmentDecision sheet: the controls and conditions that treat the risk
ISO/IEC 42001:2023Clause 6.1.4 — AI system impact assessmentUse and Factors sheets: the effect of the use on people and on the organisation
ISO/IEC 42001:2023Annex A 5.2 — AI system impact assessment processThe workbook as a whole: a set process for assessing the effect of a use
ISO/IEC 42001:2023Annex A 5.3 — Documentation of AI system impact assessmentsThe kept workbook: the assessment is documented and retained (AG-12)
EU AI Act — Regulation (EU) 2024/1689Article 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”Factors sheet, RF-6: the intended purpose the supplier states is the context in which the use is judged
EU AI Act — Regulation (EU) 2024/1689Article 5(1), points (a) to (h) — prohibited, from 2 February 2025: AI that deploys subliminal, purposefully manipulative or deceptive techniques that materially distort behaviour and cause significant harm (a); exploits vulnerabilities due to age, disability or a specific social or economic situation (b); evaluates or classifies people by social behaviour or personal characteristics, with detrimental treatment in unrelated contexts or that is unjustified or disproportionate (c); assesses the risk of a person committing a criminal offence based solely on profiling or personality traits (d); creates or expands facial recognition databases by untargeted scraping of facial images from the internet or CCTV (e); infers emotions in the areas of workplace and education institutions, except for medical or safety reasons (f); categorises people by biometric data to infer race, political opinions, trade union membership, religious or philosophical beliefs, sex life or sexual orientation (g); and, with narrow exceptions, real-time remote biometric identification in publicly accessible spaces for law enforcement (h). Regulation (EU) 2026/1744 adds points (ba) and (bb) (AI that generates or manipulates realistic intimate images of an identifiable person without consent, and AI that generates or manipulates child sexual abuse material), with Article 5(1a) and (1b), from 2 December 2026Use sheet: a possible match with a prohibited practice stops the use before any assessment
EU AI Act — Regulation (EU) 2024/1689Article 6(3) — an Annex III system is not high-risk where it “does not pose a significant risk of harm to the health, safety or fundamental rights of natural persons, including by not materially influencing the outcome of decision making”, which applies where it is intended to perform a narrow procedural task, improve the result of a previously completed human activity, detect decision-making patterns without replacing or influencing the human assessment, or perform a preparatory task; “an AI system referred to in Annex III shall always be considered to be high-risk where the AI system performs profiling of natural persons”. The provider documents the assessment before the system is placed on the market (Article 6(4))Use sheet and RF-6: a ticked Annex III area makes the use Tier 3, and Legal reads whether the Article 6(3) exemption could apply
EU AI Act — Regulation (EU) 2024/1689Article 26(4) — to the extent the deployer exercises control over the input data, it shall ensure that the input data is relevant and sufficiently representative in view of the intended purpose of the high-risk systemRF-1 and RF-3: where we control the input data, it must be relevant and representative of the intended purpose
EU AI Act — Regulation (EU) 2024/1689Article 26(9) — where applicable, deployers of high-risk systems use the information the provider gives under Article 13 to carry out their data protection impact assessment under Article 35 of Regulation (EU) 2016/679RF-2: the supplier's information on the system is used for the data protection impact assessment
EU AI Act — Regulation (EU) 2024/1689Article 27(1) — a fundamental rights impact assessment before deploying a high-risk system under Article 6(2) is required of deployers that are bodies governed by public law or private entities providing public services, and of deployers of the systems in points 5(b) and (c) of Annex III (creditworthiness, and life and health insurance pricing)RF-3 and RF-6: some deployers must assess the effect on fundamental rights before using a system in an Annex III area; Legal decides if that is us
EU AI Act — Regulation (EU) 2024/1689Article 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 2026Use sheet: the dates from which the prohibitions, the transparency duties and the Annex III duties apply, as amended
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) 2024/1689Use sheet: the amending Regulation that adds two prohibitions and moves the date for Annex III systems
NIST AI RMF 1.0GOVERN 1.3 — “Processes, procedures, and practices are in place to determine the needed level of risk management activities based on the organization’s risk tolerance.”Result sheet: the tier sets how much risk management a use needs, in line with the organisation's risk tolerance
NIST AI RMF 1.0MAP 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.”RF-6: the legal risks of the system and of its third-party components are mapped
NIST AI RMF 1.0MEASURE 2.7 — “AI system security and resilience – as identified in the MAP function – are evaluated and documented.”RF-1: security and resilience of the AI system are evaluated and documented
NIST AI RMF 1.0MEASURE 2.10 — “Privacy risk of the AI system – as identified in the MAP function – is examined and documented.”RF-2: privacy risk is examined and documented
NIST AI RMF 1.0MEASURE 2.11 — “Fairness and bias – as identified in the MAP function – are evaluated and results are documented.”RF-3: fairness and bias are evaluated and the results documented
NIST AI RMF 1.0MANAGE 1.1 — “A determination is made as to whether the AI system achieves its intended purposes and stated objectives and whether its development or deployment should proceed.”RF-5 and the Decision sheet: a determination whether the use should proceed
NIST AI RMF 1.0MANAGE 4.3 — “Incidents and errors are communicated to relevant AI actors, including affected communities. Processes for tracking, responding to, and recovering from incidents and errors are followed and documented.”Decision sheet: the review date and the conditions that bring the use back for review after an incident or error
GDPR — Regulation (EU) 2016/679Article 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’)”RF-2: personal data is limited to what the purpose needs
GDPR — Regulation (EU) 2016/679Article 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) appliesUse sheet: special category personal data never goes into an AI tool, so the use stops
GDPR — Regulation (EU) 2016/679Article 22(1) — “The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.” Article 22(3) requires, for the cases in Article 22(2), points (a) and (c), at least the right to obtain human intervention, to express a point of view and to contest the decisionUse sheet: a use that decides or shapes a decision about a person is Tier 3
GDPR — Regulation (EU) 2016/679Article 35(1) — where a type of processing, in particular using new technologies, is likely to result in a high risk to the rights and freedoms of natural persons, the controller carries out “prior to the processing” an assessment of the impact on the protection of personal data; a single assessment may address a set of similar processing operations with similar high risksRF-2 and the Decision sheet: a data protection impact assessment is considered where the processing is likely to be high risk
GDPR — Regulation (EU) 2016/679Article 35(3) — a data protection impact assessment is required in particular for a systematic and extensive evaluation of personal aspects of natural persons based on automated processing, including profiling, on which decisions with legal or similarly significant effects are based; for processing on a large scale of special categories of data; and for systematic monitoring of a publicly accessible area on a large scaleRF-2: systematic and extensive evaluation of people by automated processing is a case that needs one
NIST AI 600-1NIST AI 600-1, Artificial Intelligence Risk Management Framework: Generative Artificial Intelligence Profile, July 2024, cited by number and titleFactors sheet: the generative AI profile is a source of risks to ask about under RF-1 to RF-6

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.

These references show where this document supports an external framework. They indicate relevance only and do not reproduce the text of any standard.

Regulation (EU) 2024/1689 binds the operators of its Article 2(1): providers, deployers, importers, distributors, product manufacturers and authorised representatives. An organisation that uses another party’s AI system under its own authority for its business is a deployer (Article 3(4)). An organisation that sells goods and is called a distributor in its trade is not an AI Act distributor unless it makes an AI system available on the Union market (Article 3(7)). Which role an organisation holds for each system depends on the facts, and counsel confirms it.

The Commission’s guidelines explain how the Commission reads the Act. They are not binding, and only the Court of Justice of the European Union gives an authoritative interpretation of the Act. Member States lay down the penalties for infringements (Article 99(1)) and designate the authorities that enforce the Act, and no national text was read for these documents.

Dates are those in Article 113 as amended by Regulation (EU) 2026/1744, in force from 27 July 2026: the prohibitions and AI literacy from 2 February 2025; general-purpose AI models from 2 August 2025; the general date and Article 50 from 2 August 2026; Article 5(1) points (ba) and (bb) from 2 December 2026; high-risk systems under Annex III from 2 December 2027 and under Annex I from 2 August 2028.

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.

Prepared by Zero One Cybersecurity · Published by CISO Times

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