AICM AtlasCSA AI Controls Matrix
I&S · Infrastructure Security
I&S-05Cloud & AI Related

Production and Non-Production Environments

Specification

Separate production and non-production environments.

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, Design, Guardrails

Evaluation

Validation/Red Teaming, Re-evaluation

Deployment

Orchestration, AI Services supply chain, AI applications

Delivery

Operations, Maintenance, Continuous monitoring, Continuous improvement

Retirement

Data deletion

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 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.

Application

Owned by the Application Provider (AP)

The Application Provider (AP) is responsible 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. The AP is responsible and accountable for the implementation of the control within its own infrastructure/environment. If the control has downstream implications on the users/customers, the AP is responsible for enabling the customer and/or upstream partner in the implementation/configuration of the control within their risk management approach. The AP is accountable for carrying out the due diligence on its upstream providers (e.g MPs, Orchestrated Services) to verify that they implement the control as it relates to the service/product develop and offered by the AP. These providers build and offer end-user applications that leverage generative AI models for specific tasks such as content creation, chatbots, code generation, and enterprise automation. These applications are often delivered as software-as-a-service (SaaS) solutions. These providers focus on user interfaces, application logic, domain-specific functionality, and overall user experience rather than underlying model development. Example: OpenAI (GPTs,Assistants), Zapier, CustomGPT, Microsoft Copilot (integrated into Office products), Jasper (AI-driven content generation), Notion AI (AI-enhanced productivity tools), Adobe Firefly (AI-generated media), and AI-powered customer service solutions like Amazon Rufus, as well as any organization that develops its AI-based application internally.

Implementation guidelines

[All Actors. For the AIC 1,2,3, and 7,8 apply partially, depending on whether: The AIC is developing/hosting models.The AIC only consumes API-based AI (then relies on CSP/AP/MP to enforce).)]
1. Environment Segmentation.

2. Establish strict separation of production and non-production networks.

3. Implement access controls to restrict movement between environments.

4. Data Segregation and Masking.

5. Prohibit use of production data in non-production environments unless properly masked.

6. Enforce encryption for sensitive data used in lower environments.

7. Access Control and Least Privilege.

8. Implement role-based access control (RBAC) for environment-specific access.

9. Enforce approval processes for data migration across environments.

[Shared between the MP, AP, OSP and CSP]
10. Define strict boundaries between AI model training, testing, and production environments.

11. Enforce segmentation policies to prevent cross-environment data leakage.

12. Implement monitoring tools to detect unauthorized movements between environments.

Auditing guidelines

1. Examine Cloud Service Provider (CSP) policies and procedures that keep production and non-production environments separate to prevent unauthorized access and unintentional interactions.

2. Verify clear roles for cloud Shared Responsibility Model (e.g., between the cloud provider, cloud consumers and cloud partners).

3. Verify role-based access control (RBAC) and least-privilege principle for all environments, restricting production access to only authorized personnel.

4. Verify procedures to ensure production data is not used in non-production environments unless properly sanitized or anonymized to protect sensitive information.
 
5. Verify the change promotion process from development and testing to production, ensuring proper approvals, and documentation to maintain system integrity.
 
6. Verify that monitoring and logging are implemented across all environments to detect unauthorized access or changes, and that logs are regularly reviewed and maintained securely.
 
7. Verify that segregation controls are regularly reviewed and updated to address evolving threats and business needs, ensuring continuous protection of the production environment.

Standards mappings

ISO 42001Partial Gap
ISO/IEC 42001:2023 - No mapping
ISO/IEC 27001:2022 - A.8.31
ISO/IEC 27001:2022 - 8.27
ISO/IEC 27002 - 8.28
Addendum

No environment segregation No Technical implementation guidance No Control objectives for deployment pipeline security No Environment-specific roles or access policies No Lifecycle-phase enforcement

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, "Separate production and non-production environments."

NIST AI 600-1Full Gap
No Mapping
Addendum

No separate environments for production and non-production.

BSI AIC4No Gap
C4 PF-05
C4 DQ-06
C4 SR-06
C5 DEV-10
Addendum

N/A

AI-CAIQ questions (1)

I&S-05.1

Are production and non-production environments kept separate?