I&S-01Cloud & AI Related

Infrastructure and Virtualization Security Policy and Procedures

Specification

Establish, document, approve, communicate, apply, evaluate and maintain policies and procedures for infrastructure and virtualization security. Review and update the policies and procedures at least annually, or upon significant changes.

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

Data storage, Resource provisioning

Development

Training

Evaluation

Not applicable

Deployment

Orchestration, AI Services supply chain, AI applications

Delivery

Operations, Maintenance, Continuous monitoring

Retirement

Data deletion

Ownership / SSRM

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.

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 Model Provider-Orchestrated Service Provider (Shared MP-OSP)

The MP and OSP 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 Orchestrated Service Provider-Application Provider (Shared OSP-AP)

The OSP and AP 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.

Implementation guidelines

[All Actors]
1. Define Policy Scope: Establish clear security policies covering infrastructure components (servers, hypervisors, virtualization layers, cloud-native infrastructure).  Align with regulatory and security standards (ISO 42001, NIST 600-1, CIS Benchmarks, CSA AICM).

2. Policy Governance and Review: Assign clear ownership for policy governance. Define an annual review process incorporating changes in technology, regulatory updates, and risk landscape.

3. Training and Awareness: Develop training programs to ensure personnel understand infrastructure security policies. Conduct periodic audits to verify adherence.

Auditing guidelines

1. Examine Cloud Service Providers (CSPs) policies and procedures that defines the scope, objectives, roles, and responsibilities for Cloud (e.g., storage, processing, networking, services).

2. Verify that policies and procedures are documented and approved by senior management or governing authority and update versioning. 

3. Verify policies and procedure are effectively applied to the infrastructure and virtualization security operations s and evaluated continuously for operational effectiveness and compliance.

4. Verify if policies and procedures are regularly reviewed and updated to address emerging threats, vulnerabilities, and evolving business needs, ensuring clear documentation of changes and approvals exists.

Standards mappings

ISO 42001No Gap

ISO/IEC 42001:2023 - B.2.2
B.2.4
ISO/IEC 42001:2023 - 8.3.1
ISO/IEC 42001:2023 - 9.1
ISO/IEC 42001:2023 - 10.1
ISO/IEC 27001:2022 - A.5.1
A.8.27
A.8.9
ISO/IEC 27002 - 8.28

Addendum

N/A

EU AI ActFull Gap

No Mapping

Addendum

Full control would have to be added because the EU AI Act does not address these concerns. Add, "Establish, document, approve, communicate, apply, evaluate, and maintain policies and procedures for infrastructure and virtualization security. Review and update the policies and procedures at least annually."

NIST AI 600-1Partial Gap

GV-4.1-001
Appendix A.1.2

Addendum

The AICM control is focused on system documentation with its concern being development, quality, and ongoing maintenance of infrastructure/virtualization security documentation and policies. The AICM control should directly state that risk assessments are the annual requirement to be used to update system documentation in regards to system security.

BSI AIC4No Gap

C4 SR-06
C5 SP-01
C5 SP-02

Addendum

N/A

AI-CAIQ questions (2)

I&S-01.1

Has the organization established, documented, approved, communicated, applied, evaluated, and maintained policies and procedures for infrastructure and virtualization security?

I&S-01.2

Are these policies and procedures reviewed and updated at least annually, or upon significant changes?