SSRM Policy and Procedures
Specification
Establish, document, approve, communicate, apply, evaluate and maintain policies and procedures for the application of the Shared Security Responsibility Model (SSRM) within the organization. Review and update the policies and procedures at least annually, or upon significant changes.
Threat coverage
Architectural relevance
Lifecycle
Data storage, Team and expertise
Guardrails
Re-evaluation
Orchestration, AI Services supply chain, AI applications
Operations, Maintenance, Continuous monitoring, Continuous improvement
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
Shared Application Provider-AI Customer (Shared AP-AIC)
The AP and AIC both share responsibility and accountability 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 offer and consume.
Implementation guidelines
Auditing guidelines
1. Verify that the CSP has established and documented policies and procedures in the domain of Supply Chain Management that define organizational and technical measures to protect infrastructure and services against third‑party risks, threats, and vulnerabilities (e.g., hardware vendors, hypervisors, datacenter operators). 2. Ensure that these policies explicitly define and apply the SSRM, clearly demarcating responsibilities between CSP‑managed and customer‑managed security controls. 3. Confirm that the SSRM explicitly addresses infrastructure layers, virtualization security, multi-tenancy isolation, and controls relevant to AI workloads. 4. Inspect whether SSRM policies and procedures are compliant with relevant cloud security standards (e.g., ISO/IEC 27017, CSA CCM) and applicable regulations. 5. Verify that SSRM policies are formally approved by authorized leadership and communicated clearly to customers (e.g., through trust center, contracts, SLA) and internal stakeholders. 6. Confirm consistent SSRM enforcement across all services, with defined and auditable controls for customer onboarding, offboarding, and third‑party integrations. From CCM: 1. Examine policy for adequacy, approval, communication, currency, and effectiveness. 2. Examine policy and procedures for evidence of review at least annually.
Standards mappings
42001: A.2.2 AI Policy 42001: A.2.3 Alignment with other organizational policies 42001: A.2.4 Review of AI Policy 42001: A.10.2 Allocating Responsibilities 27001: 5.1 Leadership Commitment 27001: 5.2 Policy 27001: 5.3 Organizational roles responsibilities and authorities 27001: 7.3 Awareness 27001: 7.4 Communication 27001: 7.5 Documented Information 27001: 9.1 Monitoring measurement analysis and evaluation 27001: 9.3 Management Review 27001: A.5.1 Policies for information security 27001: A.5.2 Information security roles and responsibilities 27001: A.5.19 Information security in supplier relationships 27001: A.5.20 Addressing information security within supplier agreements 27001: A.5.22 Monitoring review and change management of supplier services 27001: A 5.23 Information security for use of cloud services 27001: A.5.37 Documented operating procedures 27001: 5.1 Policies for information security 27002: 5.2 Information security roles and responsibilities 27002: 5.19 Information security in supplier relationships 27002: 5.20 Addressing information security within supplier agreements 27002: 5.22 Monitoring review and change management of supplier services 27002: 5.23 Information security for use of cloud services 27002: 5.37 Documented operating procedures
Addendum
N/A
Article 17 (1) (l) Annex VII (5.3) Article 25
Addendum
Define or reference a Shared Security Responsibility Model (SSRM) framework, require formal policy and procedure management (documentation, approval, review), and mandate periodic review cycles and cross-actor communication of those roles.
GV-4.1-001 GV-4.1-003 GV-6.1-004
Addendum
N/A
C4 PC-02 C5 SSO-01 C5 OIS-03 C5 OIS-04 C5 PSS-01
Addendum
N/A
AI-CAIQ questions (2)
Are policies and procedures established, documented, approved, communicated, applied, evaluated, and maintained for applying the Shared Security Responsibility Model (SSRM) within the organization?
Are policies and procedures for applying the Shared Security Responsibility Model (SSRM) within the organization reviewed and updated at least annually, or upon significant changes?