HRS-09Cloud & AI Related

Personnel Roles and Responsibilities

Specification

Document and communicate roles and responsibilities of employees, as they relate to information assets and security.

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

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)

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. Establish a dedicated AI Governance Body or Committee that includes representatives from various departments such as IT, legal, compliance, engineering and research, security, finance, HR, supply chain/operations, sales, marketing, and business units. This committee should oversee the defining of policies, guidelines, and practices for the ethical and responsible development, deployment, and use of AI. This body should also oversee the implementation and compliance to AI governance policies, compliance with regulations, facilitate mitigation of AI-related risks, and ensure that AI is utilized fairly, transparently, and accountability within the organization.

2. Clear reporting lines should be established by creating a reporting hierarchy where each role knows who they report to and are accountable to. This will help in maintaining a structured flow of information and decision-making.

3. Key roles should be identified and responsibilities be defined of all stakeholders involved in AI governance. This could include key roles such as AI System Integrator, AI Data Steward, AI Architect, AI Engineer, Data Scientist, AI Ethics Compliance Officer, and AI Governance Lead.

4. Comprehensive job descriptions and terms in agreement should be developed for organizational personnel and third parties.

5. Roles and responsibilities should be communicated to all employees, contractors, and contingent staff.

6. Role-based security training commensurate with their access, duties, and responsibilities should be provided at the start of their service agreement before granting them access to corporate facilities, resources, and assets, and annually thereafter.

7. Changes to relevant policies should be communicated to employees, contractors, and contingent staff to ensure compliance with policies.

8. Feedback should be solicited from employees to identify areas of improvements.

Auditing guidelines

1. Verify the CSP's operational and security policies document the roles and responsibilities for all personnel involved in managing the cloud infrastructure.

2. Review the CSP’s public-facing Shared Responsibility Model documentation to see how they communicate their roles to customers.

Standards mappings

ISO 42001No Gap

42001: A.2.3 Alignment with other organizational policies
27001: 5.3 Organizational roles
responsibilities and authorities
27001: A.5.2 Information security roles and responsibilities
27002: 5.2 Information security roles and responsibilities

Addendum

N/A

EU AI ActPartial Gap

Article 17 (1) (m)
Article 4

Addendum

and communicate

NIST AI 600-1No Gap

GV-2.1-001
GV-1.5-001
GV-1.6-003
GV-3.2-003
GV-6.1-010
MP-4.1-003

Addendum

N/A

BSI AIC4No Gap

HR-02
HR-03
AM-05

Addendum

N/A

AI-CAIQ questions (1)

HRS-09.1

Are employee roles and responsibilities relating to information assets and security documented and communicated?