AICM AtlasCSA AI Controls Matrix
HRS · Human Resources
HRS-05Cloud & AI Related

Asset returns

Specification

Establish and document procedures for the return of organization-owned assets by terminated employees.

Threat coverage

Model manipulation
Data poisoning
Sensitive data disclosure
Model theft
Model/Service Failure
Insecure supply chain
Insecure apps/plugins
Denial of Service
Loss of governance

Architectural relevance

Physical infrastructure
Network
Compute
Storage
Application
Data

Lifecycle

Preparation

Team and expertise

Development

Supply Chain

Evaluation

Not applicable

Deployment

AI Services supply chain

Delivery

Not applicable

Retirement

Not applicable

Ownership / SSRM

PI

Shared Cloud Service Provider-Model Provider (Shared CSP-MP)

The CSP and MP are jointly responsible and accountable for the design, development, implementation, and enforcement of the control to mitigate security, privacy, or compliance risks associated with Large Language Model (LLM)/GenAI technologies in the context of the services or products they develop and offer.

Model

Owned by the Model Provider (MP)

The model provider (MP) designs, develops, and implements the control as part of their services or products to mitigate security, privacy, or compliance risks associated with the Large Language Model (LLM). Model Providers are entities that develop, train, and distribute foundational and fine-tuned AI models for various applications. They create the underlying AI capabilities that other actors build upon. Model Providers are responsible for model architecture, training methodologies, performance characteristics, and documentation of capabilities and limitations. They operate at the foundation layer of the AI stack and may provide direct API access to their models. Examples: OpenAI (GPT, DALL-E, Whisper), Anthropic(Claude), Google(Gemini), Meta(Llama), as well as any customized model.

Orchestrated

Shared Cloud Service Provider-Model Provider (Shared CSP-MP)

The CSP and MP are jointly responsible and accountable for the design, development, implementation, and enforcement of the control to mitigate security, privacy, or compliance risks associated with Large Language Model (LLM)/GenAI technologies in the context of the services or products they develop and offer.

Application

Shared across the supply chain

Shared control ownership refers to responsibilities and activities related to LLM security that are distributed across multiple stakeholders within the AI supply chain, including the Cloud Service Provider (CSP), Model Provider (MP), Orchestrated Service Provider (OSP), Application Provider (AP), and Customer (AIC). These controls require coordinated actions, communication, and governance across all involved parties to ensure their effectiveness.

Implementation guidelines

[All Actors]
1. Document Asset Return Procedures: Define clear processes for retrieving or disposing of AI assets (e.g., models, datasets, credentials) from terminated employees. Maintain an up-to-date inventory to track which assets must be returned or wiped.

2. Immediate Access Revocation: Immediately disable user accounts, API keys, tokens, and other credentials upon termination to prevent unauthorized access to AI environments and data.

3. Secure Handling and Verification: Enforce controlled mechanisms to transfer or dispose of AI assets, ensuring confidentiality (e.g., encryption) and integrity (e.g., hashing). Where relevant, require attestations or evidence of secure erasure.

4. Logging and Monitoring: Keep detailed logs of AI asset returns, modifications, and version histories, reducing the risk of unauthorized data retention or model theft.

5. Training and Coordination: Provide regular training for HR and technical teams on asset return procedures. Collaborate with relevant stakeholders (e.g., AI providers or third-party contractors) to address any security incidents stemming from delayed asset returns.

Auditing guidelines

1. Verify the CSP's employee offboarding process ensures the return of all corporate assets and the immediate revocation of all physical and logical access to data centers and cloud infrastructure.

2. Review audit logs to confirm that access is removed in a timely manner.

Standards mappings

ISO 42001No Gap
42001: A.2.3 Alignment with other organizational policies
27001: A.5.11 Return of assets
27002: 5.11 Return of assets
Addendum

N/A

EU AI ActFull Gap
No Mapping
Addendum

Establish and document procedures for the return of organization-owned assets by terminated employees.

NIST AI 600-1No Gap
GV-1.7-002
MP-4.1-003
Addendum

N/A

BSI AIC4No Gap
AM-05
Addendum

N/A

AI-CAIQ questions (1)

HRS-05.1

Are return procedures of organizationally-owned assets by terminated employees established and documented?