AICM AtlasCSA AI Controls Matrix
MDS · Model Security
MDS-03AI-Specific

Model Documentation

Specification

Define, implement, enforce, approve, document, communicate, maintain and evaluate processes and procedures for model documentation. Regularly review and update the model documentation.

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

Design, Supply Chain

Evaluation

Evaluation, Validation/Red Teaming, Re-evaluation

Deployment

AI Services supply chain, AI applications

Delivery

Operations, Continuous improvement

Retirement

Model disposal

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 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

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

[Shared Responsibilities (Applicable to MP, AP)]
1. Review and Approval Process: Organizations should establish a review process involving relevant stakeholders to review the model card and determine approval for use, based on fit and risk level. The review process and decisions made should be documented.

2. Access and Communication: Access controls should be defined for model cards, and version control should be implemented.

3. Auditing and Compliance: Model cards should be periodically audited for compliance with organizational standards and any relevant governmental regulations. The model card should be verified for completion and adherence to security standards, and the information included should be verified as accurate where applicable.

Auditing guidelines

1. Assess the CSP's controls for storing and managing model documentation provided by customers or third parties. 

2. Verify that documentation is accessible only to authorized personnel. 

3. Review procedures for maintaining the integrity and confidentiality of model documentation. 

4. Evaluate data retention policies related to model documentation. 

5. Confirm that documentation is properly backed up and protected from loss or damage.

Standards mappings

ISO 42001No Gap
42001 A.6.2.7 - AI system technical documentation
42001 B.6.2.7 - AI system technical documentation
Addendum

N/A

EU AI ActNo Gap
Article 11 (1)
Article 11 (2)
Article 13
Addendum

N/A

NIST AI 600-1Partial Gap
GV-1.2-001
MG-2.2-002
MP-1.1-002
MP-2.2-001
MS-2.9-002
MG-3.2-003
Addendum

NIST AI 600-1 speaks to documenting specific elements that would be part of a model card but does not address the formal aspects of a model card, nor its regular review, based on MDS-03 topics.

BSI AIC4No Gap
C4 PC-02
C5 SP-01
C5 SP-02
Addendum

N/A

AI-CAIQ questions (2)

MDS-03.1

Are processes and procedures defined, implemented, enforced, and evaluated for documenting, approving, communicating, evaluating, and maintaining model documentation?

MDS-03.2

Is the model documentation regularly reviewed and updated?