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An AI governance framework your company can operate

AI governance defines who can approve an AI use, what evidence they need, and who responds when it causes a problem. For a COO or CIO, the work starts with an inventory, decision rights, and controls that employees can follow.

Discuss AI governance with SymphSymph's AI transformation approach

What belongs in an AI governance framework?

A company's framework connects policy to everyday decisions across the AI lifecycle: selecting a tool, approving data access, testing a use case, releasing it, monitoring it, and retiring it. It applies to purchased AI tools as well as systems your team builds. The controls should reflect the use's impact on people, the sensitivity of its data, and the actions it can take.

Separate three decisions: whether the vendor is acceptable, whether a particular workflow is acceptable, and whether the people using it are prepared. Approval of a tool does not automatically approve every use of that tool.

This guide provides operational guidance, not legal advice. Ask qualified legal and privacy advisers to determine the laws, sector requirements, and contractual obligations that apply to your organisation and each use case.

Choose public frameworks for the job they do

These references serve different purposes. Use their official sources to check scope and current requirements. The implementation suggestions below are Symph's practical guidance, not a claim of certification or compliance.

NIST AI Risk Management Framework 1.0

NIST's voluntary AI RMF 1.0 organises AI risk management into four functions: Govern, Map, Measure, and Manage. Govern is cross-cutting. The functions support iterative work across the lifecycle; they are not a linear checklist or a certification scheme.

  • Govern: establish policies, accountability, risk tolerance, and oversight.
  • Map: understand the use's purpose, context, users, affected people, and potential impacts.
  • Measure: evaluate risks and system performance with suitable tests and evidence.
  • Manage: prioritise and treat risks, monitor the system, and respond to incidents.

Use it to structure your use-case risk review and the evidence a release decision needs. NIST is revising version 1.0; this guide describes the published 2023 version.

Read the NIST AI RMF 1.0 core

ISO/IEC 42001:2023

ISO/IEC 42001 specifies requirements for establishing, implementing, maintaining, and continually improving an artificial intelligence management system. It covers organisations providing or using AI products or services and applies a Plan-Do-Check-Act approach to management.

Use it when you need a formal management system with documented responsibilities, processes, and continual improvement. Implementing selected practices or buying an AI tool does not make an organisation ISO/IEC 42001 certified.

Read ISO's description of ISO/IEC 42001

European Union AI Act

The EU AI Act is law, rather than a voluntary governance framework. The European Commission explains its risk-based approach through unacceptable risk, high risk, transparency risk (often called limited risk), and minimal or no risk. Unacceptable practices are prohibited; high-risk uses carry specific requirements. Certain uses, such as chatbots and deepfakes, have transparency obligations. General-purpose AI models also have separate obligations.

Have legal advisers assess territorial scope, your role as provider or deployer, the system's intended purpose, exceptions, and applicable dates. Do not treat an internal low-risk rating as an AI Act classification. A minimal-risk label under the Act does not remove obligations under other laws.

Read the European Commission's AI Act guidance

Singapore Model AI Governance Framework, second edition

The 2020 framework from Singapore's IMDA and PDPC offers voluntary guidance in four areas: internal governance structures and measures; determining the level of human involvement in AI-augmented decision-making; operations management; and stakeholder interaction and communication. Its guiding principles are explainable, transparent, and fair decision-making, and human-centric AI.

Use its questions to decide how people supervise AI decisions and how you communicate with affected stakeholders. The second edition primarily addresses organisations deploying AI solutions at scale. Adoption does not establish legal compliance; do not confuse this edition with later generative-AI guidance.

Read Singapore's second-edition framework (PDF)

Set up governance in seven operating steps

Start with an existing management or risk forum if it can make the decisions. Name the people responsible and record the evidence for each approval. Add specialist review where the use case requires it.

  1. Inventory the tools and uses

    Ask each department which AI tools, assistants, and embedded features it uses. Record the business purpose, owner, vendor, users, data sources, permissions, outputs, and any actions the system can take. Include experiments and employee-selected tools, not only procurement's list.

  2. Assign decision rights

    Make a business owner accountable for the outcome. Give IT responsibility for access and technical controls; involve security and privacy owners for their reviews, and legal advisers for applicable obligations. Specify who may approve a pilot, accept residual risk, release it, and suspend it. Employees need one clear route for submitting a new use.

  3. Set policy and triage rules

    Publish approved tools, allowed data, prohibited uses, and review requirements. Triage by potential harm, sensitive data, external exposure, autonomy, and reversibility. A private drafting aid and a system recommending employment decisions need different scrutiny. Define which uses must wait for specialist review and which are prohibited.

  4. Review data and suppliers

    Confirm permission to use each source and test that users see only information they are authorised to access. Review vendor retention, model-training use of inputs, subprocessors, incident terms, and exit arrangements. Record unresolved questions; an enterprise label alone does not answer them.

  5. Evaluate before release

    Test representative tasks and foreseeable failures, including unsupported answers, data leakage, prompt injection, and inappropriate actions. Include affected groups where relevant. Set acceptance criteria before testing, document limitations, and assign a human reviewer who has enough information and authority to reject the output. Keep a fallback and rollback procedure.

  6. Monitor and handle incidents

    Track output errors, employee reports, access issues, and changes in how people use the system. Give users a reporting channel. Define who can restrict access, preserve relevant evidence without exposing more sensitive data, investigate, communicate with affected people, and restore service. Record corrective actions and any external reporting decisions with the right advisers.

  7. Review changes and retire uses

    Reassess when the model, vendor terms, data source, permissions, workflow, or intended audience changes, and after a significant incident. Schedule periodic reviews appropriate to the risk. When a use ends, remove access and integrations, handle retained data under your policy, and record why it was retired.

A minimum use-case approval record

Keep one record per use case. A spreadsheet can work at the start if ownership, access, and version history are clear. Include these fields:

  • Use-case name, purpose, business owner, sponsor, and review date.
  • Vendor, model or product version, users, connected systems, and permitted actions.
  • Data sources, classification, permission evidence, retention, and access boundaries.
  • People affected, expected benefit, potential harms, risk rating, and reasons for it.
  • Required controls, human review, evaluation criteria, test evidence, and known limitations.
  • Approval decision, approver, conditions, residual risks, and next review triggers.
  • Monitoring owner, incident contact, suspension authority, and fallback or retirement plan.

Example: an internal policy assistant can answer from approved policy documents but must not change employee records. The policy owner reviews source accuracy; IT tests permissions; employees receive a route for reporting a wrong answer. Expanding the assistant to recommend disciplinary action requires a fresh use-case review.

Keep governance working in Sustain

In Symph's AI transformation approach, Sustain covers adoption tracking, governance, and refresher sessions as models evolve. Discuss how that phase fits your existing operating reviews: who owns the AI inventory, which uses need reassessment, and what employees need to learn when tools change.

Bring one current AI use and its approval record to the conversation. We can discuss the gaps between the written policy and how employees use the tool.

Read Symph's AI transformation approach or discuss governance for your team.

Frequently asked questions

Who should own AI governance in a company?

Name an executive sponsor with authority over business risk and an accountable business owner for each use. IT, security, privacy, legal, and relevant department leaders contribute to decisions within their responsibilities. Record who can approve, release, suspend, and retire a use.

Is an acceptable-use policy enough?

A policy needs operating processes behind it: an inventory, a new-use review, data and access checks, evaluation, human oversight, monitoring, and incident response. Employees also need training and a clear way to ask questions or report problems.

Does following a public AI framework guarantee compliance?

No. Voluntary frameworks and management standards can support governance, but legal obligations depend on jurisdiction, sector, the system, and your role. Qualified advisers should assess applicable requirements. This guide does not provide legal advice or certify compliance.