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ISO 42001: 2023 - A.3.2 AI Roles and Responsibilities

This article provides guidance on how to implement the ISO 42001:2023 control A.3.2 AI Roles and Responsibilities

ISO 42001 Control Description

Roles and responsibilities for AI shall be defined and allocated according to the needs of the organisation.

Control Objective

To establish accountability within the organisation to uphold its responsible approach for the implementation, operation and management of AI systems.

Purpose

To ensure clear accountability throughout the organisation for AI-related activities across the AI system lifecycle. Defining roles and responsibilities prevents gaps in oversight, reduces confusion about who is accountable for AI decisions, and ensures all critical areas of AI management are covered by appropriately qualified individuals.

Guidance on Implementation

What Should Inform Role Definition

When assigning AI roles and responsibilities, the organisation should consider:

  1. AI policies - Roles needed to implement and maintain compliance with AI policy (Control A.2.2)
  2. AI objectives - Roles required to achieve AI objectives (Clause 6.2)
  3. Identified risks - Roles needed to manage AI-specific risks identified through risk assessment (Clause 6.1.2)
  4. AI system impact assessments - Roles responsible for conducting and acting on impact assessments (Clause 6.1.4)
  5. Lifecycle stage coverage - Roles needed across all applicable AI system lifecycle stages (ISO/IEC 5338)
  6. Organisational context - Size, complexity, and maturity of AI usage

Areas Requiring Defined Roles and Responsibilities

The organisation should define roles and responsibilities for:

a) Risk management
  • AI risk identification and assessment
  • Risk treatment planning and implementation
  • Risk monitoring and reporting
b) AI system impact assessments
  • Conducting assessments
  • Reviewing and approving assessment results
  • Implementing measures to address impacts
c) Asset and resource management
  • Managing data resources (Control A.4.3)
  • Managing tooling resources (Control A.4.4)
  • Managing computing resources (Control A.4.5)
d) Security
  • AI system security
  • Protection of models and training data
  • Adversarial attack prevention and response
e) Safety
  • Safety assurance for safety-critical AI systems
  • Incident investigation and response
f) Privacy
  • Privacy compliance (GDPR, CCPA, etc.)
  • Data subject rights management
  • Privacy impact assessments
g) Development
  • AI system design and architecture
  • Model development and training
  • Testing and validation
h) Performance
  • Monitoring AI system performance
  • Detecting and responding to drift
  • Continuous validation
i) Human oversight
  • Defining oversight requirements
  • Implementing oversight mechanisms
  • Escalation procedures
j) Supplier relationships
  • Managing third-party AI providers
  • Supplier assessment and monitoring
  • Contract management
k) Legal compliance
  • Regulatory compliance monitoring
  • Legal requirement implementation
  • Liaison with regulators
l) Data quality management
  • Data acquisition and preparation
  • Data quality assessment and monitoring
  • Data lifecycle management (throughout lifecycle)

Key AI Roles to Consider

Organisations may need to define responsibilities for roles such as (reference ISO/IEC 22989 Section 5.19):

Strategic and governance roles:

  • AI governance committee or board
  • Chief AI Officer or AI lead
  • AI ethics committee members
  • Data Protection Officer (for AI involving personal data)

Development roles:

  • AI developers / data scientists / ML engineers
  • AI system architects
  • Data engineers
  • Domain experts / subject matter experts
  • Software engineers (for non-AI components)

Operational roles:

  • AI system operators
  • AI system users
  • Human oversight personnel
  • Performance monitoring specialists

Assurance roles:

  • Internal auditors (AI management system)
  • Compliance officers
  • Risk managers
  • Quality assurance personnel

Implementation Steps

Organisations should:

  1. Identify all AI-related activities across the AI system lifecycle that require assignment of responsibility
  2. Map activities to roles - Determine which role(s) will be responsible, accountable, consulted, and informed (RACI matrix useful)
  3. Define role descriptions - Document for each role:
    • Key responsibilities
    • Authority level
    • Required competencies (link to Control A.4.7)
    • Reporting lines
    • Interfaces with other roles
  1. Consider prioritisation - Organisations can prioritise how roles are assigned based on risk levels and organisational maturity
  2. Define to appropriate level - Responsibilities should be defined with sufficient detail for individuals to understand and perform their duties effectively
  3. Assign individuals - Allocate specific persons to roles, ensuring they have necessary competence
  4. Communicate roles - Ensure all personnel understand their own responsibilities and those of others they interact with
  5. Document role assignments - Maintain records of who holds which responsibilities
  6. Review periodically - Reassess roles as AI usage evolves, organisational structure changes, or new risks emerge

Key Considerations

Avoid concentration of responsibility: Don't assign all AI-related responsibilities to one person or team, as this creates single points of failure and accountability gaps.

Separation of duties: For critical activities, consider separating development, validation, and approval responsibilities to ensure appropriate checks and balances.

Cross-functional coordination: AI systems often span multiple functions (IT, legal, business units). Clearly define interfaces and handoffs between roles.

Third-party considerations: When using third-party AI systems or services, clearly define which responsibilities remain with the organisation versus the supplier.

Scalability: Role definitions should be scalable - able to grow as AI usage expands without complete reorganisation.

Competence alignment: Role assignment should be informed by competence requirements (Control A.4.7). Ensure assigned individuals have or can acquire necessary skills.

Integration with existing roles: Where possible, integrate AI responsibilities into existing organisational roles rather than creating entirely parallel structures, particularly for smaller organisations.

Documentation

Document roles and responsibilities in:

  • Job descriptions
  • RACI matrices
  • Organisational charts
  • Process documentation
  • Governance frameworks
  • Delegation of authority documents

Related Controls

Within ISO/IEC 42001:

  • A.2.2 AI policy
  • A.3.3 Reporting of concerns
  • A.4.7 Competence
  • A.5.2 AI system impact assessment process
  • Clause 5.3 Roles, responsibilities and authorities

Integration with ISO 27001 (if applicable):

  • A.5.2 Information security roles and responsibilities