AI Compass
Compass

Approval process

How an AI deployment gets assessed, decided and documented, without turning into a procedure that creates shadow AI.

·2 min read·By Fachbereich Governance
DETAIL
2 sections

Two routes

RouteWhenDurationDecision
FastNo personal data, no Annex III, approved tooldaysBusiness area with a checklist
ThoroughPersonal data, new provider, Annex III, employee dataweeksDesignated function with legal and data protection

The fast route matters more. Without it, low-risk cases bypass the procedure too, and the inventory becomes incomplete.

The checklist for the fast route

  • Which task, how often, with what expected result?
  • Which data actually flows into the input?
  • Is the tool approved, and for this kind of data?
  • Who checks the output before it leaves the building?
  • Who is responsible, by name?

Five questions, one page, one decision. If any answer is "unclear", the case goes to the thorough route.

The thorough route

  1. 01

    Purpose and boundary in writing

    What the system is to do and expressly not. That determines the classification.

  2. 02

    Determine role and class

    Provider or deployer, class under the AI Act, with reasoning.

  3. 03

    Assess data protection

    Legal basis, purpose limitation, processing on behalf, third-country element, impact assessment where required.

  4. 04

    Settle consultation

    Works council or staff representation where employees are affected.

  5. 05

    Decide and record

    With conditions, a review cycle and named ownership.

The inventory entry

FieldContent
System and versionWhat exactly, in which build
Purpose and boundaryFor what, and expressly not for what
RoleProvider or deployer, with reasoning
ClassUnder the AI Act, with reasoning and date
Data categoriesWhat is actually processed
Legal basisWith a pointer to the balancing test where relevant
Provider and contractsProcessing agreement, locations, sub-processors
Responsible personBy name
Overseeing personBy name, at high risk
ConditionsWhat must hold for the approval to carry
Review cycle and dateWhen to reassess

That table is simultaneously the answer to a supervisory enquiry. Anyone keeping it has nothing to assemble in an incident.

Triggers for reassessment

  • Change of the underlying model, including by the provider without notice.
  • Extension of the purpose or of the user group.
  • New data categories in the input.
  • Change of provider or of a sub-processor.
  • An incident or a noticeable drop in quality.
  • Expiry of the review cycle.

The first row needs a contractual provision: the provider must be obliged to announce model changes. Without that clause the trigger cannot be noticed.

Folding in shadow AI

  1. 01

    Search rather than ask

    Check network logs and expense claims for provider access. That finds more than any survey.

  2. 02

    Amnesty

    Whoever reports gets an assessment rather than a sanction. Without that promise nobody reports.

  3. 03

    Decide fast

    Rule on reported cases within two weeks, or the amnesty evaporates.

  4. 04

    Offer an alternative

    A ban without a replacement only produces better-hidden shadow AI.

Related courses and sources

ArticleFreeDE · EN

Fraunhofer IAIS on artificial intelligence

German-language guidance on auditing, certifying and operating AI systems, from applied research.

For German-language audit and certification questions where English sources do not help.

Fraunhofer IAISGo to offer
ArticleFreeEN

NIST AI RMF Playbook

The practical build-out of the risk framework: concrete suggestions per function on what to do and what to document.

For anyone building an internal risk assessment who wants an outline that has already been thought through.

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Approval process