AICM AtlasCSA AI Controls Matrix
SEF · Security Incident Management, E-Discovery, & Cloud Forensics
SEF-09Cloud & AI Related

Incident Response

Specification

Define incident categories and severity levels for AI systems, and determine response procedures for each, including automated response where applicable.

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

Development

Guardrails

Evaluation

Re-evaluation

Deployment

Orchestration, AI Services supply chain, AI applications

Delivery

Operations, Maintenance, Continuous monitoring, Continuous improvement

Retirement

Data deletion

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. Incident Response Planning: Define AI-specific incident categories, informed by frameworks like Mitre ATLAS, and establish severity levels based on risk. Document decision trees for responses to each incident type.

2. Detection and Analysis: Implement logging capabilities as defined in LOG controls in order to detect anomalies and indicators of poisoning. Implement output validation specified in AIS-09. Set up alerts for when these metrics should be considered incidents.

3. Response Automation: Develop response playbooks and automate responses to incidents where applicable, such as blocking output if output validation fails or removing a model from use if data provenance is found to be invalid. Keep logging of any automated incident responses. 

4. Testing/Validation: Implement testing of automated response systems. Periodically review response effectiveness.

5. Compliance: Meet regulatory requirements for incident reporting and maintain documentation for auditing purposes.

Auditing guidelines

1. Verify incident response categories and severity levels clearly documented (e.g, consider impacts to instance, region, single or multi-tenant).

2. Verify approaches for automatic detection and response (e.g., AWS Security Hub, Guard Duty, Lambda; Microsoft Cloud Defender; Google Chronicle and Security Command Center).

3. Confirm well-defined roles and escalation pathways during incident response.

4. Check documented incident response timelines and service level agreements (SLAs).

5. Ensure regular reviews of incident response activities and outcomes.

6. Verify clear accountability documented for incident handling.

7. Confirm training provided to relevant stakeholders on incident response processes.

Standards mappings

ISO 42001Partial Gap
42001: A.8.4
42001: A.8.5
42001: B.8.4
42001: B.8.5
27001: A.5.25
27002: A.5.26
Addendum

ISO 42001 defines types of incidents that must be communicated, not incident categories and severity levels as AICM.

EU AI ActFull Gap
No Mapping
Addendum

Define incident categories and severity levels for AI systems and determining response procedures.Specifically require the establishment of a comprehensive framework for categorizing incidents and determining appropriate response procedures as outlined in SEF-09.

NIST AI 600-1Partial Gap
MG-2.4-002
MG-2.4-003
MG-2.4-004
Addendum

NIST AI 600-1 doesn't reference incident categories and severity levels, only escalating procedures in general, and does not take into consideration automated response.

BSI AIC4No Gap
C4 RE-05
C5 SIM-01
Addendum

N/A

AI-CAIQ questions (1)

SEF-09.1

Are incident categories and severity levels defined for AI systems, and response procedures determined for each, including automated response where applicable?