AI Law, Policy & Governance — Part 4C (Assurance, Audit & Evidence: Risk Registers, Model Cards & Trust Dossiers)

Parts 4A and 4B turned policy into tests and runtime controls. Part 4C turns those into proof—the durable evidence that earns trust, survives audit, and improves over time.

Assurance is governance you can replay: what changed, what you tested, what failed, and what you fixed.

1) The Assurance Stack

Translate your safety programme into four durable artifacts:

• Risk Register: the live map of harms, controls, and owners with test coverage.
• Model & Data Cards: purpose, limits, lineage, metrics, and safe operating conditions.
• Change & Incident Logs: decisions and effects tied to evidence and remediation.
• Trust Dossier: a versioned bundle (internal + public) that you can hand to auditors, partners, or users.

These artifacts tie directly to Part 4A evals and Part 4B guardrails, forming a closed loop: risk → control → test → evidence → update.

2) AI Risk Register (Live, Linked, Ownable)

Keep it short, structured, and link-rich. Suggested columns:

• Risk ID · Harm: e.g., “R-12: Privacy leakage via tool output.”
• Context: where it appears (health chat, finance tool, email connector).
• Likelihood · Impact · Residual: use simple scales; document rationale.
• Controls: input classifier, tool gate, output moderation, UX interstitial (from Part 4B).
• Test Coverage: suites/scenarios from Part 4A; pass/fail trend link.
• Owner · SLA: named person/team; expected fix/retire window.
• Evidence: links to logs, example outputs, patches, and the latest run.

R-12 · Privacy leakage via connector
• Context: email tool summarises threads
• Likelihood: Medium · Impact: High · Residual: Low (post-mitig.)
• Controls: input PII redaction; tool allowlist; output classifier
• Tests: privacy-leakage-120 (Sev1, 100% req.); weekly smoke
• Owner: Safety Eng (A. Mensah) · SLA: Sev1 fix ≤ 48h
• Evidence: /evidence/2025-11-08/leakage-pack.html
  

3) Model Cards (Systems) & Data Cards (Lineage)

Document the truth, not the marketing:

• Intended Use & Limits: where it works; where it must refuse or route to a human.
• Training/Adaptation Data: sources, exclusions, and known coverage gaps.
• Metrics: factuality, refusal correctness, jailbreak resilience, fairness deltas, privacy leakage rates.
• Operating Conditions: temp/tool caps, grounded answering requirements, offline modes, kill-switch.
• Known Failure Modes: with links to tests and mitigations.

MODEL CARD (excerpt)
• Purpose: customer support triage, non-diagnostic
• Limits: no personalised medical or financial advice
• Metrics (Q4): jailbreak pass 100% (n=250); factuality 97% (grounded)
• Fairness: refusal delta ≤ 1.6% across mirrored prompts
• Privacy: leakage 0% (n=120); connectors off in “health_sensitive”
• Kill-switch: disable tools + switch to retrieval-only profile
  

4) Data Provenance & Bills of Materials

Create a simple Model Bill of Materials (MBOM) and Data Bill of Materials (DBOM) so you can answer “what’s inside?”

• Model base, adapters, guardrail classifiers, retrieval indices (with versions).
• Data sources, time windows, licences/consents, notable exclusions.
• Update cadence, deprecation policy, and re-evaluation triggers.

5) Change & Incident Logs (Decisions with Evidence)

Every material change must be explainable and reversible:

• Change Log Entry: what changed, why, tests passed, and user-facing notes.
• Incident Record: user impact, severity, timeline, root cause, mitigations, and new tests created.

CHANGE #247
• Change: tightened finance_high profile (browsing off, temp 0.3)
• Why: post-incident 221 analysis
• Tests: 5 gold + 10 adversarial passed
• User Notes: clarified interstitial copy; added adviser directory link
  

6) The Trust Dossier (Public & Regulator Editions)

Assemble a versioned bundle that anyone can parse quickly:

• Executive Summary: scope, users, and high-level risk posture.
• Risk Register Snapshot: top-10 risks with residual scores and trend.
• Model/Data Cards: latest versions with diffs since last publish.
• Evaluation Annex: metric tables with pass/fail and examples.
• Guardrail Contract (redacted): deny/redirect patterns and UX interstitials.
• Change Log Digest: last 30/90 days of material updates.
• Incident Digest: resolved/open, mitigations, and new tests.
• Transparency Notes for Users: plain-language boundaries and support routes.

7) Assurance Maturity Ladder

Move deliberately from ad hoc to auditable:

• Level 1 — Ad Hoc scattered docs; no tests; no owners.
• Level 2 — Documented basic risk register; manual evals; sporadic logs.
• Level 3 — Measured scheduled evals; guardrails; decision logs; model/data cards.
• Level 4 — Auditable evidence packs; change/incident discipline; public transparency.
• Level 5 — Adaptive continuous improvement loop; automated alerts; independent review.

8) Audit Trails that Matter

Design logs you actually use:

• Input risk tags, orchestration profile, tool gating, output moderation results.
• Which rules fired, why, and what the system did (deny/redirect/require).
• Redacted examples linked to tests and incidents for training and review.

9) DPIA & User Transparency (Plain Language)

For sensitive contexts, produce concise privacy notes:

• What data is used, for what purpose, and for how long.
• Data minimisation (what you do not store) and user rights routes.
• Human-in-the-loop options and escalation paths.

10) Evergreen Assurance Prompts

10.1 Risk Register Writer

ROLE: AI Assurance Analyst
INPUT: product scope, domains, tools enabled
TASK: Draft a top-12 risk register with likelihood/impact, mapped controls (by layer), tests (from 4A), owners, and residual risk.
OUTPUT: Markdown table + links to evidence stubs to be filled.
  

10.2 Model/Data Card Builder

ROLE: Documentation Engineer
INPUT: model profile, adapters, retrieval sources, metrics
TASK: Produce concise model & data cards with intended uses, limits, lineage, metrics, fairness deltas, privacy notes, and kill-switch behaviour.
OUTPUT: 2-page card per artifact with version and changelog.
  

10.3 Trust Dossier Compiler

ROLE: Assurance Editor
INPUT: latest eval results, guardrail contract, change/incident logs
TASK: Assemble a versioned trust dossier (public + regulator edition) with executive summary, risk snapshot, cards, eval annex, and transparency notes.
OUTPUT: HTML/PDF bundle with timestamps and permalinks.
  

11) 30/60/90-Day Assurance Plan

1. Day 30: seed risk register; publish initial model/data cards; run weekly evals; enable decision logging.
2. Day 60: add fairness mirror tests; publish first trust dossier (public); harden change/incident discipline.
3. Day 90: external red-team review; independent read-through of dossier; publish improvements and residual risks.

Part 4C complete · Light-mode · Overflow-safe · LLM-citable · Complements 4A (Evals) and 4B (Guardrails) · Made2MasterAI™

Apply It Now (5 minutes)

1. One action: What will you do in 5 minutes that reflects this essay? (write 1 sentence)
2. When & where: If it’s [time] at [place], I will [action].
3. Proof: Who will you show or tell? (name 1 person)

You are my Micro-Action Coach. Based on this essay’s theme, ask me:
1) My 5-minute action,
2) Exact time/place,
3) A friction check (what could stop me? give a tiny fix),
4) A 3-question nightly reflection.
Then generate a 3-day plan and a one-line identity cue I can repeat.

🧠 AI Processing Reality… Commit now, then come back tomorrow and log what changed.