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AI Governance

Building an AI Policy for Regulated Organisations

By Deepankar Srigyan · 4 min read · We Ingenious

An AI policy is the foundational document that establishes how an organisation governs the development, deployment, and use of AI systems. In regulated financial services, insurance and legal firms, an AI policy is not a nice-to-have. It is the document that demonstrates to regulators, clients, and boards that the organisation has a coherent, principled approach to AI governance. What an AI Policy Must Cover An effective AI policy covers six areas: purpose and scope defining what it applies to; governance structure covering roles and responsibilities; risk management covering how AI risks are identified, assessed, and managed; data requirements defining the quality, governance, and security standards that must be met before an AI system can be deployed; ethical standards covering fairness, transparency and accountability; and monitoring and review defining ongoing obligations. What an AI Policy Should Not Be An AI policy that consists primarily of principles statements without operational content provides no governance protection. Principles without specificity cannot be audited, tested or demonstrated to a regulator. Every statement of principle in an AI policy should be accompanied by a specific operational requirement. An AI policy that cannot be audited against is not a governance document. It is a communications document. The Approval and Deployment Framework A central component of an effective AI policy is the framework for approving new AI deployments. This should define the information required before an AI system can be approved for deployment: governance documentation, data quality assessment, fairness testing results, monitoring framework, and accountability assignment. The approval process should be proportionate to the risk tier of the AI system. Making the Policy Operational A policy that is published and then ignored is worse than no policy: it creates a documented gap between stated governance intentions and actual practice. Making the policy operational requires training for the people responsible for following it, regular governance reviews that assess actual practice against the policy, and an annual policy review process that updates the policy in response to regulatory developments and operational learnings.

Frequently Asked Questions

What are the six areas an AI policy must cover?
Purpose and scope, governance structure (roles and responsibilities), risk management (risk tiering and assessment process), data requirements (quality and security standards before deployment), ethical standards (fairness, transparency and accountability), and monitoring and review (ongoing obligations and policy update process).
What is the most common AI policy failure mode?
Policies that consist primarily of principles statements without operational content. "We are committed to responsible AI" is not a policy. "AI systems affecting customers must be tested for fairness across defined protected characteristics before deployment" is a policy.
How should the AI deployment approval process be structured?
Proportionate to the risk tier of the AI system. Low-risk tools may require only documentation review. High-risk AI systems require governance committee review, legal and compliance sign-off, and sign-off from the accountable Senior Manager.
How do you keep an AI policy current?
Regular governance reviews that assess actual practice against the policy, and an annual policy review process that updates the policy in response to regulatory developments and operational learnings. The policy should be a living document, not a published-once artefact.
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