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Appendix · AWS

AI Governance Toolkit

Ready-to-adapt governance artefacts for AIB-C01 — an operating model, RACI, intake form, risk register, risk-tier control matrix, tool-classification policy, launch and incident checklists, vendor due diligence, and how AWS controls map onto them.

This is a set of ready-to-adapt artefacts for the governance work Domain 3 tests: an operating model, a RACI, a use-case intake form, a risk register, a risk-tier to control matrix, a tool-classification policy, launch and incident checklists, and a vendor due-diligence set. It is independent preparation, not an official AWS compliance framework — adapt every artefact to your own regulatory obligations before you rely on it. The AIB-C01 beta exam does not ask you to configure any of this; it asks you to recognise which structure, control or accountability fits a scenario. Everything here stays at that decision level.

Governance by design

The recurring Domain 3 discriminator is when governance enters. The tempting answer reviews a system just before launch; the correct answer builds classification, oversight mode and monitoring into project planning from the start (task 3.1.3). When a stem describes a control added late, the better option almost always moved it earlier.

The toolkit at a glance

text
Use case ──▶ INTAKE FORM ──▶ RISK CLASSIFICATION ──▶ CONTROL SET
│ │ │
│ ▼ ▼
│ RISK REGISTER HUMAN OVERSIGHT
│ (owned rows) + MONITORING
▼ │
OPERATING MODEL (who decides) ◀── RACI ────────┤
│ ▼
▼ LAUNCH READINESS
TOOL CLASSIFICATION │
(approved/blocked/eval) ▼
INCIDENT RESPONSE

Each artefact answers a different governance question. Read down the diagram: intake captures the request, classification sets the tier, the tier drives the control set, the operating model and RACI say who decides, and launch and incident procedures close the loop.

1. AI governance operating model

Governance fails in two opposite ways: a single committee that becomes a bottleneck, or no forum at all so decisions happen by accident. The operating model names a small number of bodies, gives each clear decision rights, and sets a cadence. It maps directly to task 3.2.1 (cross-functional representation and clear accountability).

BodyMembershipMay decideMay not decideCadence
AI steering committeeExecutive sponsor, CIO/CTO, line-of-business heads, financePortfolio priorities, budget, risk appetite, scale/pause/terminateIndividual prompt wording, technical architectureQuarterly
AI governance councilLegal, compliance, security, data owner, responsible-AI lead, business repRisk-tier definitions, policy, high-tier launch approval, escalation outcomesWhich vendor a team likes best without a risk viewMonthly + on escalation
Responsible-AI reviewResponsible-AI lead, data scientist, domain expert, affected-user advocateFairness/oversight adequacy, mitigation sign-off for medium+ tiersBusiness ROI targetsPer high/medium use case
Use-case working groupProduct owner, technical lead, business analystDay-to-day delivery, low-tier launch within policyAnything outside its tier’s delegated authorityWeekly

The design rule is delegated authority by tier: low-risk use cases clear at the working-group level so governance does not throttle volume, while high-risk use cases rise to the council. A body that cannot say no is not a governance body; each row’s “may not decide” column is deliberate.

2. RACI across the AI lifecycle

A RACI stops the two classic accountability failures: everyone assumes someone else owns a control, or one person is accountable for everything and therefore for nothing. Responsible does the work, Accountable owns the outcome (exactly one per row), Consulted gives input before, Informed hears after.

ActivityBusiness ownerData ownerResponsible-AI leadLegal / complianceSecurityGovernance council
Use-case intakeA/RCCIII
Risk classificationCCRCCA
Data approvalCA/RCCCI
Model / build-buy-partner choiceA/RCCCCI
Launch approval (high tier)CCCCCA/R
Production monitoringARCICI
Incident responseCCCCRA

The exam signal: when a stem says “no one was clearly responsible for X after launch”, the fix is a named A in the monitoring or incident row — not a new tool. Note that data approval is accountable to the data owner, not the business owner who wants to use it; that separation is what prevents a team from waving its own data through.

3. Use-case intake form

Intake is the cheapest place to say no. A structured form forces a proposal to state its outcome, its data and its risk before anyone spends money, and it feeds prioritisation (task 2.1.3) and classification (task 3.2.4).

  • Sponsor and business owner — named individual, not a team.
  • Problem and current baseline — what the process costs or takes today, measured (link to the KPI Library baseline methods).
  • Proposed outcome and target — the specific metric that should move, and by how much.
  • Why AI, not rules — the deterministic-vs-AI test (task 1.2.1); if the logic is fixed, this is a rule engine.
  • Data required — sources, sensitivity, ownership, whether it may leave the org, quality state.
  • Consequence of a wrong output — reversible or not, who is affected, regulated or not.
  • Human-in-the-loop point — where a person reviews before an action is taken.
  • Build / buy / partner leaning — with a rough cost and timeline.
  • Success and kill criteria — the numbers that would make you scale, pause or terminate.

A proposal that cannot fill “consequence of a wrong output” and “kill criteria” is not ready for a budget decision. That is the intake gate doing its job.

4. Risk register template with worked rows

The register is the living record the exam expects to exist before production, not after an incident. Each row names an owner, a likelihood and impact, the current control and a residual rating. These worked rows span the risk categories the guide lists (accuracy, privacy, security, IP, regulatory, reputational, workforce).

IDRisk categoryDescriptionLikelihoodImpactOwnerMitigation / controlResidual
R-01Accuracy / reliabilitySupport assistant gives wrong policy answers (hallucination)MediumHighSupport leadContextual grounding check against policy KB; escalation on low confidenceMedium
R-02PrivacyCustomer PII pasted into prompts and retainedMediumHighData ownerPII redaction filter; retention set to minimum; staff trainingLow
R-03SecurityPrompt-injection via user-supplied text drives unintended actionLowHighSecurityGuardrails denied topics; no autonomous write actions; human approvalLow
R-04Intellectual propertyGenerated marketing copy reproduces third-party protected contentMediumMediumLegalOutput review for regulated claims; vendor IP indemnity confirmedMedium
R-05Regulatory / complianceAutomated eligibility decision falls under regulated decisioningLowHighComplianceRisk-tier = high; human decision-maker retained; audit logLow
R-06ReputationalPublic-facing bot produces an offensive or off-brand responseMediumHighBrand / commsContent filters; red-team before launch; kill switch and holding messageMedium
R-07WorkforceStaff fear role loss and disengage from the rolloutHighMediumChange leadTransparent comms on role change to oversight; reskilling pathMedium

The teaching point is that likelihood-times-impact drives the tier, the tier drives the control, and the residual rating is what the governance council actually signs off — not the raw risk. A row with no named owner is not a managed risk.

5. Risk-tier to control-set matrix

This is the artefact that turns “apply a risk classification framework” (task 3.2.4) into something a reader can use tomorrow. Classify the use case by consequence and reach, then read the control set across the row. It mirrors the tiered logic of the EU AI Act and the NIST AI RMF without citing article numbers, which is exactly the level the exam tests.

TierTypical use caseApprovalsHuman oversight modeMonitoring cadenceDocumentationEscalation
MinimalInternal draft assistance, brainstormingWorking groupHuman-in-the-loop optional; author reviews own outputSpot-check quarterlyUse-case entry onlyTo council if scope grows
LimitedInternal knowledge search, summarisationWorking group + responsible-AI noteHuman reviews before external useMonthly samplingIntake + register rowsTo council on incident
HighCustomer-facing decisions, content, or adviceGovernance councilHuman-in-the-loop on each consequential actionWeekly metrics + drift watchFull register, evaluation evidence, AI Service Card reviewImmediate to council + sponsor
UnacceptableManipulative, unlawful, or safety-critical without recourseDo not proceedN/AN/ARejection recordedTerminate at intake

The oversight column carries the exam’s core distinction: human-in-the-loop means a person approves before the action, human-on-the-loop means a person monitors and can intervene, and human-in-command means a person can override and shut down. Higher consequence pushes you up that ladder.

6. AI tool classification policy — the answer to shadow AI

Task 1.2.4 is explicit: a transparent classification of tools as approved / blocked / under evaluation is the concrete answer to shadow AI. Banning everything drives usage underground; approving everything abandons control. The policy names states and the criteria that move a tool between them.

A tool is approved for a stated set of use cases when it has cleared due diligence: data-use terms acceptable, no training on your data by default, residency and retention meet policy, security review passed, and an owner is named. Approval is scoped — approved for internal drafting is not approved for customer PII. Movement out: a term change, an incident, or a failed re-review moves it to under evaluation or blocked.

text
request ──▶ UNDER EVALUATION ──▶ APPROVED (scoped)
│ │
hard criterion term change /
fails incident
▼ ▼
BLOCKED ◀────────────┘
│
re-request ──▶ UNDER EVALUATION

The exam signal for shadow AI is always visibility plus a sanctioned path, never a blanket ban.

7. Launch readiness checklist

Before a use case goes live, the sponsor confirms each item. This operationalises “envision → launch” from AWS CAF and the transition to production-grade from task 4.4.5.

  • Risk tier assigned and control set applied.
  • Baseline metric captured before go-live (you cannot claim value later without it).
  • Human-oversight point defined and staffed for the chosen tier.
  • Guardrails / content filters configured and tested against known-bad inputs.
  • Monitoring and drift-detection in place with named owner and alert thresholds.
  • Kill switch and rollback path tested; a holding message ready.
  • Incident runbook written and the response owner (RACI A) briefed.
  • Data terms, residency and retention confirmed; vendor indemnity on file.
  • Success and kill criteria agreed by the steering committee.
  • Workforce communication sent; affected staff know what changes.

8. Incident response outline for AI failures

AI incidents differ from classic IT outages: the system stays “up” while producing harmful, biased or wrong output. The outline names phases and owners.

Sources: monitoring alert (accuracy drop, drift, bias-drift), user or customer complaint, red-team finding, or a regulatory query. Log time, use case, tier and suspected category (accuracy, bias, privacy, security, IP, reputational).

9. Vendor due-diligence question set

Build-buy-partner (task 2.1.2) usually lands on buy or partner, which makes vendor scrutiny a governance control, not a procurement formality. Ask every vendor:

AreaQuestionA weak answer looks like
Data useHow is our data used, and is it used to improve or train your models?“It may be used to improve the service” with no opt-out
TrainingIs training on our data off by default, and can we contractually prohibit it?Off “on request” only, or unclear
RetentionHow long is our content retained, and can we set it to zero / minimum?Fixed long retention with no control
ResidencyIn which regions is our data stored and processed?Cannot commit to a region we require
IndemnityDo you indemnify us against third-party IP claims on generated output?No IP indemnity, or heavily capped
Evaluation evidenceWhat evaluation, bias and safety evidence can you share?Marketing claims, no methodology or data
Roadmap riskWhat is your model deprecation and change policy, and notice period?Models change with little notice; lock-in risk
Sub-processorsWho are your sub-processors and where do they operate?Undisclosed or non-committal

The discriminator on a vendor-selection item is rarely price; it is usually a data-use, indemnity or residency answer that a cheaper vendor cannot give.

10. How AWS’s own controls map onto these artefacts

The exam does not require you to configure any AWS control, but it expects you to recognise which AWS capability supports which governance artefact. Keep this at the mapping level.

Governance needAWS capability (strategic view)Where it maps
Stop harmful, off-topic or unsafe outputAmazon Bedrock Guardrails — content filters, denied topics, PII redaction, contextual grounding (hallucination) checksRisk register controls; launch checklist; incident containment
Detect and explain biasAmazon SageMaker Clarify — bias detection across data prep, after training and in the deployed model, plus explainabilityResponsible-AI review; register bias rows; tier control set
Catch drift and inaccurate predictions in productionAmazon SageMaker Model Monitor — alerts on inaccurate predictions from deployed modelsMonitoring cadence rows; incident detection
Transparency on intended use and limitsAWS AI Service Cards — intended use cases, limitations, responsible-AI design choicesVendor evidence; high-tier documentation
Who is accountable for whatAWS shared responsibility model for AI — AWS secures the cloud; the customer owns data, access, use-case appropriateness and whether output is fit for purposeOperating model and RACI accountability

The single most-tested idea in this table: no managed service removes the customer’s accountability for what the system is used for and whether its output is fit for purpose. Guardrails and Clarify are tools that support your controls; they are not a substitute for the operating model, the tiering and the human oversight that you own.

Key takeaways

  • Governance is a set of bodies with decision rights and a cadence, not one committee; delegate low tiers so volume is not throttled.
  • Every managed risk and every lifecycle activity has exactly one accountable owner — the fix for “no one owned it” is a name, not a tool.
  • Classify first: tier drives approvals, oversight mode, monitoring cadence, documentation and escalation.
  • Shadow AI is answered by a transparent approved / blocked / under-evaluation policy with a sanctioned path and a substitute for anything blocked.
  • Capture the baseline before launch and write the incident runbook before you need it.
  • Vendor due diligence — data use, training, retention, residency, indemnity, evidence, roadmap — is a governance control, not paperwork.
  • AWS Guardrails, Clarify, Model Monitor and AI Service Cards support these artefacts; shared responsibility keeps use-case and fitness accountability with you.

Last updated Sep 18, 2026