
The European Union's AI Act is poised to fundamentally alter artificial intelligence governance, development, and application. Many of the creative businesses in my portfolio already run with strong GDPR compliance programs and sophisticated ISO 27001 Information Security Management Systems (ISMS), hence this new rule offers both possibilities and difficulties for those kind of businesses.
The favorable news is if you have any, your current obligations to data protection and information security offer a major head start. This is about strategic integration not about beginning from nothing. This guidance will enable you to efficiently negotiate the EU AI Act using your existing frameworks.
GDPR, ISO 27001 and AI Act
Adding still another significant control initially seems difficult. These three models, though, are quite complimentary:
- From prohibited to moderate risk, the EU AI Act takes a risk-based approach classifying AI systems and putting strict rules on "high-risk" AI systems connected to risk management, data governance, technical documentation, transparency, human oversight, and cybersecurity.
- Emphasizing a continuous risk management cycle and providing a wealth of Annex A controls directly applicable to securing AI systems and the data they process, ISO 27001:2022 offers the blueprint for your ISMS.
- With ideas of lawfulness, fairness, openness, and responsibility that are basic to responsible artificial intelligence, particularly when personal data is used for training or operation, GDPR controls the treatment of personal data.
The recurring link is a methodical, risk-based governance model. Businesses which have already embraced this via GDPR and ISO 27001 are positioned to adjust.
Where to Start?
For AI Act compliance, current ISMS and data security policies are great assets:
- Risk Management: Current procedures for risk assessment and treatment directly apply to ISO 27001. Although the approach is currently in place, you will have to enhance this to add risks particular to artificial intelligence (e.g., algorithmic bias, model flaws, data poisoning).
- Security Controls: Many ISO 27001 Annex A controls—e.g., access control, secure development, change management, incident response, supplier security—form the cornerstone for securing AI systems and their surroundings.
- Strong Data Governance: GDPR has already incased personal data handling discipline. For artificial intelligence systems especially with regard to quality, representativeness, and possible biases in training data as well as guaranteeing legal processing, this is absolutely vital.
- Document Control Discipline: For high-risk systems, the AI Act requires copious of technical documentation. ISO 27001 method of handling recorded data offers the required structure.
- Supplier Due-Diligence: Your current supplier security processes can be improved to evaluate AI component suppliers or AI-as-a-service providers.
- Incident Management Framework: AI component suppliers or AI-as-a-service providers. Processes for handling security events can be modified to fit AI system failures or security breaches.
What to Do?
Here is a useful, strategy to assist your businesses in incorporating AI Act requirements:
Step 1: Observe and Assess
- Create an AI system inventory. First, you need to find all the AI systems that your company makes, uses, or buys. This includes AI components that is included into operational tools, digital solutions, or apps that people use.
- Classify AI Systems by Risk: Critically look at each system in light of the EU AI Act's four risk categories: unacceptable, high-risk, limited-risk, and minimal-risk. For definitions of high risk, pay special attention to Article 6 and Annex III. An AI used to help people get basic services, grade students, or hire people, for example, may be very dangerous
- Analyze gaps: For AI systems that are known to be high-risk, compare your current ISMS controls, QMS processes (if you are ISO 9001 certified), and GDPR protections to the rules of the AI Act.
Step 2: Improve and Integrate
- Embed AI into Risk Management: Use AI in your ISMS risk assessment process to deal with dangers that are peculiar to this field. Use the specific risk-management method that Article 9 of the AI Act says to use for high-risk AI.
- Data Governance for AI: To improve quality, reduce bias, and follow the law (AI Act Article 10), make sure your GDPR data governance includes data used for training, validating, and testing AI.
- Create technical documentation. According to Annex IV of the AI Act, you must provide ways to create and keep the complete technical documentation needed for high-risk systems. Your document control methods are very important here.
- Apply record-keeping and log-keeping: Make sure that your present logging and monitoring systems can work with high-risk AI systems and that you can keep track of how they work (AI Act Article 12).
- Transparency & Human Oversight: Make sure that your systems and procedures meet the requirements for transparency set out in Article 13 and 52 of the AI Act. For high-risk AI, use AI Act Article 14 to set up effective human oversight procedures.
- Prioritize: Put accuracy, robustness, and cybersecurity at the top of your list for AI. Add the requirements of Article 15 of the AI Act to your operational security policies and the safe development lifecycle (SDLC). This includes full testing and validation.
Step 3: Preserve Continuous compliance
- Conformity Assessments (for High-Risk AI): Before AI systems that are considered high-risk are sold or used, establish a way to check their compliance.
- Integrate with Quality Management: Article 17 of the AI Act says that your QMS must cover the entire life of high-risk AI systems, from design to post-market monitoring, to make sure you are following the rules.
- Post-market monitoring: Once the AI systems are in place, keep an eye on them, collect data on how well they work, and write down important events (AI Act Article 72).
- Update Documentation and Train the Teams: Review and revise any Statement of Applicability, ISMS/QMS rules, and procedures that are relevant. Give development, legal, compliance, and product teams training on the AI Act and your company's AI governance structure
The Strategic Advantage
For the businesses in our portfolio, proactive EU AI Act compliance box tick-through is not only about fulfilling legal obligations. Regarding:
- Building Trust: Showing ethical artificial intelligence methods helps consumers, partners, and users to develop trust.
- Mitigating Risk: Reducing the possibility of major financial penalties and damage to reputation can help to mitigate risk.
- Responsible Innovation: Encouragement of responsible innovation is building a structure that lets creativity flourish while controlling possible negative effects.
- Market Access & Differentiation: Compliance will be a main facilitator for entering the EU market and can be a major competitive difference.
- Valuation: Strong governance—including artificial intelligence ethics and compliance—is progressively viewed as a sign of a mature and profitable organization.
The Future
The EU AI Act will be implemented gradually. Right now is the preparation period. Businesses can create a cohesive and effective method of AI governance by using ISO 27001 ISMS and GDPR foundations.
I am encouraging the companies in my portfolio to begin their AI system inventory and conduct an initial risk classification immediately. In addition to ensuring compliance, adopting an integrated, risk-based approach will enhance your overall governance and prepare you for a future shaped by artificial intelligence.