AICM AtlasCSA AI Controls Matrix
SEF · Security Incident Management, E-Discovery, & Cloud Forensics
SEF-08Cloud & AI Related

Points of Contact Maintenance

Specification

Maintain points of contact for applicable regulation authorities, national and local law enforcement, and other legal jurisdictional authorities. Review and update the points of contact at least annually.

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 collection, Data curation, Data storage, Resource provisioning, Team and expertise

Development

Supply Chain, Guardrails, Training, Design

Evaluation

Evaluation, Validation/Red Teaming, Re-evaluation

Deployment

Orchestration, AI Services supply chain, AI applications

Delivery

Operations, Continuous monitoring

Retirement

Archiving, Data deletion, Model disposal

Ownership / SSRM

PI

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

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]
1. Establish and maintain a centralized registry of designated points of contact (PoCs) for security, compliance, and incident response across all participating entities.

2. Ensure contact information includes role-specific PoCs for legal, regulatory, compliance, security, and DevSecOps functions, along with backup personnel.

3. Define procedures to regularly verify and update PoC information, especially when there are organizational changes, role transitions, or partner onboarding/offboarding.

4. Ensure availability of PoC data during incident triage and e-discovery, with clearly assigned responsibilities for rapid engagement.

5. Maintain contact retention and access procedures in alignment with applicable regulatory or contractual requirements (e.g., GDPR, HIPAA, CJIS).

Auditing guidelines

1. Verify documented procedures for Cloud Service Provider (CSP) to meet regulatory responsibilities and maintain points of contact.

2. Verify procedures for review of dependencies with OSP, MP, AIC and AP that would impact the Application Provider's ability to meet its regulatory contact obligations (e.g., GDPR, CIRCIA, NIS2, nation CSIRTs).

3. Confirm regular updates and validation of points of contact.

4. Check records clearly document responsibility for points of contact maintenance.

5. Ensure immediate updates to contact information upon role changes.

6. Confirm periodic audits validating the accuracy and availability of contacts.

Standards mappings

ISO 42001No Gap
42001: A.8.4
42001: A.8.5
42001: B.8.4
42001: B.8.5
Addendum

N/A

EU AI ActFull Gap
No Mapping
Addendum

Maintain points of contact with regulatory authorities, law enforcement, and legal jurisdictional authorities.

NIST AI 600-1No Gap
MG-2.3-001
MG-4.3-003
Addendum

N/A

BSI AIC4No Gap
C4 PC-01
C5 OIS-05
Addendum

N/A

AI-CAIQ questions (2)

SEF-08.1

Are points of contact maintained for applicable regulation authorities, national and local law enforcement, and other legal jurisdictional authorities?

SEF-08.2

Are the points of contacts reviewed and updated at least annually?