Assess whether a shadow system must be decommissioned this quarter (e249d4)

Situation

A shadow system must sits with HR analytics governance lead because a DPA inquiry about training on European user data hit a bank preparing for a model-risk exam. Evidence is generative-AI acceptable-use policy draft; write the AI Governance Policy and Oversight option that extract can carry.

Decision

HR analytics governance lead in a bank preparing for a model-risk exam must choose Policy or governance breach / Model defect / Dual failure / Hold for the missing fact using generative-AI acceptable-use policy draft after a DPA inquiry about training on European user data.

Hypotheses to test

• Authorize Policy or governance breach now; generative-AI acceptable-use policy draft already has the discriminator after a DPA inquiry about training on European user data.
• Keep Model defect in force until generative-AI acceptable-use policy draft is completed after a DPA inquiry about training on European user data for HR analytics governance lead.
• Treat generative-AI acceptable-use policy draft as Dual failure because both readings appear after a DPA inquiry about training on European user data.
• Refuse a AI Governance close: HR analytics governance lead does not have the page a shadow system must turns on in generative-AI acceptable-use policy draft.

Analysis required

• Verify data provenance and the human-oversight gate HR analytics governance lead can actually point to.
• Walk the model input/output path recorded in generative-AI acceptable-use policy draft and mark each hop approved, shadow, or unlogged.
• Verify data provenance and the human-oversight gate HR analytics governance lead can actually point to.
• For this AI Governance Policy and Oversight file, read generative-AI acceptable-use policy draft against a DPA inquiry about training on European user data and write the one fact that would move a shadow system must for HR analytics governance lead.

Recommendation

Choose Policy or governance breach / Model defect / Dual failure / Hold for the missing fact on this AI Governance / Policy and Oversight packet (generative-AI acceptable-use policy draft after a DPA inquiry about training on European user data). The follow-on Policy and Oversight action is what HR analytics governance lead does next: implement the option, assign an owner, and log the missing fact.

Command returns

• Bottom-line AI Governance option on a shadow system must, then the evidence in generative-AI acceptable-use policy draft, then the action for HR analytics governance lead
• Hypothesis scorecard against generative-AI acceptable-use policy draft: supported / rejected / untestable
• Named option among Policy or governance breach, Model defect, Dual failure and the fact that kills the others
• Owner and next date for HR analytics governance lead in a bank preparing for a model-risk exam