bmad-plus 0.7.5 → 0.9.0

package/src/bmad-plus/packs/pack-shield/references/iso42001/iso42001-clauses-requirements.md

@@ -1,279 +1,279 @@
-# ISO/IEC 42001:2023 — Mandatory Clause Requirements (Clauses 4–10)
-
-All clauses are mandatory regardless of organisational size, sector, or role (provider or user). This reference covers each clause in detail with required outputs, audit evidence, and common nonconformities.
-
----
-
-## Clause 4 — Context of the Organisation
-
-### 4.1 Understanding the Organisation and Its Context
-**Requirement:** Determine external and internal issues relevant to the AIMS purpose and that affect the ability to achieve intended outcomes. Include AI-specific factors: regulatory environment, societal expectations of AI, market pressures to adopt AI, and technology risks.
-
-**Required outputs:**
-- Environmental/contextual analysis (PESTLE or equivalent) covering AI dimensions
-- List of external issues: AI regulations (EU AI Act, national AI laws), public trust, competitive AI landscape
-- List of internal issues: AI maturity, data infrastructure, staff competence, ethical culture
-
-**Audit evidence:** Meeting minutes, strategic planning documents, AIMS scope document.
-
-### 4.2 Understanding the Needs and Expectations of Interested Parties
-**Requirement:** Identify all parties affected by or interested in the AIMS and their requirements.
-
-**AI-specific interested parties:**
-- Individuals affected by AI decisions (customers, citizens, employees)
-- Regulators (data protection authorities, sector-specific regulators, AI regulators)
-- AI model providers/vendors
-- Civil society and advocacy groups
-- Employees who interact with or are affected by AI
-- Investors and insurers requiring AI governance assurance
-
-**Required outputs:** Stakeholder register with requirements matrix.
-
-### 4.3 Determining the Scope of the AIMS
-**Requirement:** Document the boundary and applicability of the AIMS — which AI systems, processes, organisational units, and locations are in scope.
-
-**Key scope decisions:**
-- Which AI systems are in scope? (All? Only high-impact? Only AI systems developed in-house?)
-- Are AI systems used by third parties on the organisation's behalf in scope?
-- Which organisational functions (R&D, operations, customer service) are included?
-
-**Required outputs:** AIMS Scope Document — must specify: what is included, what is explicitly excluded, and the justification for exclusions.
-
-**Common nonconformity:** Scope excludes AI tools used in HR (e.g., AI screening tools) without documented justification.
-
-### 4.4 AI Management System
-**Requirement:** Establish, implement, maintain, and continually improve the AIMS including all processes and their interactions.
-
----
-
-## Clause 5 — Leadership
-
-### 5.1 Leadership and Commitment
-**Requirement:** Top management must demonstrate active commitment to the AIMS — not just sign documents, but actively support AI governance as a strategic priority.
-
-**Evidence of commitment:**
-- AI policy approved and signed by senior leadership (CEO, Board, or equivalent)
-- AI governance included in management meeting agendas
-- Resources allocated for AIMS implementation
-- AI-related KPIs/objectives set at leadership level
-
-**Audit tip:** Auditors will interview top management — leaders must be able to explain the AIMS scope and their personal role in AI governance.
-
-### 5.2 AI Policy
-**Requirement:** Top management must establish an AI Policy that:
-- Is appropriate to the organisation's purpose and context
-- Provides a framework for setting AI objectives
-- Includes commitment to responsible and ethical AI
-- Includes commitment to comply with applicable requirements
-- Includes commitment to continual improvement of the AIMS
-
-**AI Policy must also address (ISO 42001-specific):**
-- The organisation's responsible AI principles (fairness, transparency, accountability, safety, privacy, reliability, inclusivity)
-- Commitment to conduct AI risk and impact assessments
-- Human oversight of AI systems proportionate to risk/impact
-
-**Required outputs:** AI Policy document (documented, communicated, available to interested parties as appropriate).
-
-### 5.3 Organisational Roles, Responsibilities and Authorities
-**Requirement:** Define roles accountable for AI governance.
-
-**Minimum required roles:**
-| Role | Responsibilities |
-|------|----------------|
-| AIMS Owner (top management) | Strategic accountability for AIMS; approves AI policy |
-| AI Risk Owner (per AI system) | Accountable for AI risk assessment and treatment decisions |
-| AI System Owner | Day-to-day management of specific AI system in scope |
-| Data Governance Lead | Accountable for A.7 data controls |
-| AIMS Internal Auditor | Conducts internal AIMS audits |
-| AI Incident Manager | Manages AI-specific incident response |
-
-**Required outputs:** RACI matrix or roles/responsibilities document; job descriptions updated.
-
----
-
-## Clause 6 — Planning
-
-### 6.1 Actions to Address Risks and Opportunities
-**Requirement:** Plan how to address risks and opportunities relevant to the AIMS context and objectives.
-
-#### 6.1.1 General
-Determine risks and opportunities that could affect AIMS achievement. Plan actions to address them.
-
-#### 6.1.2 AI Risk Assessment and AI System Impact Assessment (AISIA)
-**This is the most distinctive clause in ISO 42001.** Two separate assessments are required:
-
-**AI Risk Assessment:**
-- Identify risks associated with AI systems (model risks, data risks, operational risks, supply chain risks)
-- Assess likelihood and severity
-- Determine treatment: modify, accept, avoid, or transfer
-- Document results and decisions
-- Must be repeated when AI systems change significantly or on a defined schedule
-
-**AI System Impact Assessment (AISIA):**
-- Assess potential impacts on individuals and society (not just organisational risk)
-- Consider: who is affected, what decisions the AI makes, how severe and reversible the impact is
-- Classify impact level (Low / Medium / High) → drives control selection
-- Must be performed for each AI system in scope
-- Must be updated when the AI system's purpose or operating context changes
-
-**Required outputs:**
-- AI Risk Assessment register (per AI system or per risk category)
-- AISIA records (per AI system)
-- Risk treatment decisions documented
-
-**Common nonconformity:** AISIA completed once during implementation but never revisited; risk assessment covers organisational risk only, not AI-specific risks.
-
-#### 6.1.3 AI Risk Treatment
-**Requirement:** Select and implement risk treatment options for AI risks identified in 6.1.2. Prepare a risk treatment plan with ownership, timelines, and residual risk acceptance.
-
-**Statement of Applicability (SoA):**
-- List all 38 Annex A controls
-- For each: applicable or not? Justification. Implementation status.
-- Exclusions of applicable controls must be justified — "not currently a priority" is not sufficient
-
-### 6.2 AI Objectives and Planning to Achieve Them
-**Requirement:** Establish AI objectives at relevant functions and levels.
-
-**AI objectives must be:**
-- Consistent with the AI policy and responsible AI principles
-- **Measurable** (not aspirational only)
-- Monitored and communicated
-- Updated as appropriate
-
-**Examples of measurable AI objectives:**
-- Achieve bias score below X across demographic groups in AI system Y by Q3
-- Complete AISIA for all in-scope AI systems by [date]
-- Achieve 100% AI awareness training completion for all staff by [date]
-- Reduce AI incident mean time to resolution (MTTR) below X hours
-- Achieve ISO 42001 certification by [date]
-
----
-
-## Clause 7 — Support
-
-### 7.1 Resources
-**Requirement:** Provide resources needed for AIMS: budget, personnel, tooling, infrastructure.
-
-**AI-specific resource considerations:**
-- Data labelling/annotation capacity and quality assurance
-- Model evaluation and testing infrastructure
-- AI ethics expertise (internal or external)
-- Legal and regulatory monitoring for AI law changes
-
-### 7.2 Competence
-**Requirement:** Determine competence needed for AI roles; provide training; evaluate effectiveness.
-
-**Competence requirements by role:**
-| Role | Competence Areas |
-|------|----------------|
-| AI developers | Responsible AI practices, fairness-aware ML, secure ML development |
-| AI system operators | Understanding AI system limitations, human oversight procedures, incident detection |
-| Compliance/risk staff | AIMS clause requirements, AISIA methodology, AI risk assessment |
-| Procurement | AI-specific supplier due diligence, contractual AI requirements |
-| All staff | AI acceptable use policy, what AI is being used for, how to report AI concerns |
-
-**Required outputs:** Competence matrix, training records, training effectiveness evaluations.
-
-### 7.3 Awareness
-**Requirement:** All persons working under the organisation's authority must be aware of: the AI policy, their contribution to AIMS effectiveness, consequences of non-conformance.
-
-### 7.4 Communication
-**Requirement:** Determine internal and external communications relevant to AIMS: what to communicate, when, to whom, how.
-
-**AI-specific communications:**
-- External: transparency disclosures to AI-affected individuals (links to A.8.2 and A.8.5)
-- Internal: AI incident alerts, policy updates, training announcements
-- Regulatory: AI incident notifications where required
-
-### 7.5 Documented Information
-**Requirement:** Maintain and retain documented information required by ISO 42001, plus any the organisation determines necessary for AIMS effectiveness.
-
-**Mandatory documented information (retain):**
-- AIMS scope document
-- AI policy
-- AI risk assessment records
-- AISIA records
-- SoA
-- AI objectives
-- Internal audit reports and results
-- Management review records
-- Nonconformities and corrective actions
-
----
-
-## Clause 8 — Operation
-
-### 8.1 Operational Planning and Control
-**Requirement:** Plan, implement, and control processes to meet AIMS requirements; implement control plans; manage planned changes; address unintended changes.
-
-**Key operational controls:**
-- AI system development follows documented lifecycle (A.6)
-- Data governance controls applied (A.7)
-- Impact assessments completed before deployment
-- Change management process for AI systems — reassess risk/impact when systems change
-
-### 8.2 AI Risk Assessment
-**Requirement:** Execute AI risk assessments per the method established in 6.1.2. Retain documented results.
-
-### 8.3 AI Risk Treatment
-**Requirement:** Implement the risk treatment plan. Retain documented evidence of treatment.
-
----
-
-## Clause 9 — Performance Evaluation
-
-### 9.1 Monitoring, Measurement, Analysis and Evaluation
-**Requirement:** Monitor and measure AI system performance, AIMS process effectiveness, and progress against AI objectives.
-
-**Metrics to consider:**
-- AI system performance metrics (accuracy, precision/recall, bias scores) vs defined thresholds
-- AISIA completion rate across in-scope AI systems
-- AI incident count, severity, and MTTR
-- SoA control implementation progress
-- Training completion rates
-- Supplier AI assessment completion rates
-
-**Required outputs:** Monitoring reports, dashboard or metrics register.
-
-### 9.2 Internal Audit
-**Requirement:** Conduct internal audits at planned intervals to determine AIMS conformance and effective implementation.
-
-**Audit programme requirements:**
-- Audit frequency defined (typically annual minimum)
-- Auditor competence and independence — cannot audit own work
-- Audit plan covering all AIMS clauses and applicable controls over the audit cycle
-- Audit reports with findings, nonconformities, and opportunities for improvement
-- Audit records retained
-
-### 9.3 Management Review
-**Requirement:** Top management reviews the AIMS at planned intervals.
-
-**Management review agenda must cover:**
-- Status of actions from previous reviews
-- Changes in external/internal issues affecting the AIMS
-- AI risk and impact assessment results
-- Performance and metrics against AI objectives
-- Internal audit results
-- Nonconformities and corrective actions
-- Opportunities for improvement
-
-**Required outputs:** Management review minutes with decisions and action items.
-
----
-
-## Clause 10 — Improvement
-
-### 10.1 Continual Improvement
-**Requirement:** Continually improve the suitability, adequacy, and effectiveness of the AIMS.
-
-### 10.2 Nonconformity and Corrective Action
-**Requirement:** When a nonconformity occurs: react, control, evaluate root cause, implement corrective action, review effectiveness.
-
-**AI-specific nonconformity examples:**
-- AI system deployed without completed AISIA
-- Training data bias testing skipped for a model
-- AI incident not reported within required timeframe
-- Staff using public AI tools without following acceptable use policy
-- Supplier AI assessment overdue
-
-**Required outputs:** Nonconformity records, corrective action log with root cause, action taken, and effectiveness review.
+# ISO/IEC 42001:2023 — Mandatory Clause Requirements (Clauses 4–10)
+
+All clauses are mandatory regardless of organisational size, sector, or role (provider or user). This reference covers each clause in detail with required outputs, audit evidence, and common nonconformities.
+
+---
+
+## Clause 4 — Context of the Organisation
+
+### 4.1 Understanding the Organisation and Its Context
+**Requirement:** Determine external and internal issues relevant to the AIMS purpose and that affect the ability to achieve intended outcomes. Include AI-specific factors: regulatory environment, societal expectations of AI, market pressures to adopt AI, and technology risks.
+
+**Required outputs:**
+- Environmental/contextual analysis (PESTLE or equivalent) covering AI dimensions
+- List of external issues: AI regulations (EU AI Act, national AI laws), public trust, competitive AI landscape
+- List of internal issues: AI maturity, data infrastructure, staff competence, ethical culture
+
+**Audit evidence:** Meeting minutes, strategic planning documents, AIMS scope document.
+
+### 4.2 Understanding the Needs and Expectations of Interested Parties
+**Requirement:** Identify all parties affected by or interested in the AIMS and their requirements.
+
+**AI-specific interested parties:**
+- Individuals affected by AI decisions (customers, citizens, employees)
+- Regulators (data protection authorities, sector-specific regulators, AI regulators)
+- AI model providers/vendors
+- Civil society and advocacy groups
+- Employees who interact with or are affected by AI
+- Investors and insurers requiring AI governance assurance
+
+**Required outputs:** Stakeholder register with requirements matrix.
+
+### 4.3 Determining the Scope of the AIMS
+**Requirement:** Document the boundary and applicability of the AIMS — which AI systems, processes, organisational units, and locations are in scope.
+
+**Key scope decisions:**
+- Which AI systems are in scope? (All? Only high-impact? Only AI systems developed in-house?)
+- Are AI systems used by third parties on the organisation's behalf in scope?
+- Which organisational functions (R&D, operations, customer service) are included?
+
+**Required outputs:** AIMS Scope Document — must specify: what is included, what is explicitly excluded, and the justification for exclusions.
+
+**Common nonconformity:** Scope excludes AI tools used in HR (e.g., AI screening tools) without documented justification.
+
+### 4.4 AI Management System
+**Requirement:** Establish, implement, maintain, and continually improve the AIMS including all processes and their interactions.
+
+---
+
+## Clause 5 — Leadership
+
+### 5.1 Leadership and Commitment
+**Requirement:** Top management must demonstrate active commitment to the AIMS — not just sign documents, but actively support AI governance as a strategic priority.
+
+**Evidence of commitment:**
+- AI policy approved and signed by senior leadership (CEO, Board, or equivalent)
+- AI governance included in management meeting agendas
+- Resources allocated for AIMS implementation
+- AI-related KPIs/objectives set at leadership level
+
+**Audit tip:** Auditors will interview top management — leaders must be able to explain the AIMS scope and their personal role in AI governance.
+
+### 5.2 AI Policy
+**Requirement:** Top management must establish an AI Policy that:
+- Is appropriate to the organisation's purpose and context
+- Provides a framework for setting AI objectives
+- Includes commitment to responsible and ethical AI
+- Includes commitment to comply with applicable requirements
+- Includes commitment to continual improvement of the AIMS
+
+**AI Policy must also address (ISO 42001-specific):**
+- The organisation's responsible AI principles (fairness, transparency, accountability, safety, privacy, reliability, inclusivity)
+- Commitment to conduct AI risk and impact assessments
+- Human oversight of AI systems proportionate to risk/impact
+
+**Required outputs:** AI Policy document (documented, communicated, available to interested parties as appropriate).
+
+### 5.3 Organisational Roles, Responsibilities and Authorities
+**Requirement:** Define roles accountable for AI governance.
+
+**Minimum required roles:**
+| Role | Responsibilities |
+|------|----------------|
+| AIMS Owner (top management) | Strategic accountability for AIMS; approves AI policy |
+| AI Risk Owner (per AI system) | Accountable for AI risk assessment and treatment decisions |
+| AI System Owner | Day-to-day management of specific AI system in scope |
+| Data Governance Lead | Accountable for A.7 data controls |
+| AIMS Internal Auditor | Conducts internal AIMS audits |
+| AI Incident Manager | Manages AI-specific incident response |
+
+**Required outputs:** RACI matrix or roles/responsibilities document; job descriptions updated.
+
+---
+
+## Clause 6 — Planning
+
+### 6.1 Actions to Address Risks and Opportunities
+**Requirement:** Plan how to address risks and opportunities relevant to the AIMS context and objectives.
+
+#### 6.1.1 General
+Determine risks and opportunities that could affect AIMS achievement. Plan actions to address them.
+
+#### 6.1.2 AI Risk Assessment and AI System Impact Assessment (AISIA)
+**This is the most distinctive clause in ISO 42001.** Two separate assessments are required:
+
+**AI Risk Assessment:**
+- Identify risks associated with AI systems (model risks, data risks, operational risks, supply chain risks)
+- Assess likelihood and severity
+- Determine treatment: modify, accept, avoid, or transfer
+- Document results and decisions
+- Must be repeated when AI systems change significantly or on a defined schedule
+
+**AI System Impact Assessment (AISIA):**
+- Assess potential impacts on individuals and society (not just organisational risk)
+- Consider: who is affected, what decisions the AI makes, how severe and reversible the impact is
+- Classify impact level (Low / Medium / High) → drives control selection
+- Must be performed for each AI system in scope
+- Must be updated when the AI system's purpose or operating context changes
+
+**Required outputs:**
+- AI Risk Assessment register (per AI system or per risk category)
+- AISIA records (per AI system)
+- Risk treatment decisions documented
+
+**Common nonconformity:** AISIA completed once during implementation but never revisited; risk assessment covers organisational risk only, not AI-specific risks.
+
+#### 6.1.3 AI Risk Treatment
+**Requirement:** Select and implement risk treatment options for AI risks identified in 6.1.2. Prepare a risk treatment plan with ownership, timelines, and residual risk acceptance.
+
+**Statement of Applicability (SoA):**
+- List all 38 Annex A controls
+- For each: applicable or not? Justification. Implementation status.
+- Exclusions of applicable controls must be justified — "not currently a priority" is not sufficient
+
+### 6.2 AI Objectives and Planning to Achieve Them
+**Requirement:** Establish AI objectives at relevant functions and levels.
+
+**AI objectives must be:**
+- Consistent with the AI policy and responsible AI principles
+- **Measurable** (not aspirational only)
+- Monitored and communicated
+- Updated as appropriate
+
+**Examples of measurable AI objectives:**
+- Achieve bias score below X across demographic groups in AI system Y by Q3
+- Complete AISIA for all in-scope AI systems by [date]
+- Achieve 100% AI awareness training completion for all staff by [date]
+- Reduce AI incident mean time to resolution (MTTR) below X hours
+- Achieve ISO 42001 certification by [date]
+
+---
+
+## Clause 7 — Support
+
+### 7.1 Resources
+**Requirement:** Provide resources needed for AIMS: budget, personnel, tooling, infrastructure.
+
+**AI-specific resource considerations:**
+- Data labelling/annotation capacity and quality assurance
+- Model evaluation and testing infrastructure
+- AI ethics expertise (internal or external)
+- Legal and regulatory monitoring for AI law changes
+
+### 7.2 Competence
+**Requirement:** Determine competence needed for AI roles; provide training; evaluate effectiveness.
+
+**Competence requirements by role:**
+| Role | Competence Areas |
+|------|----------------|
+| AI developers | Responsible AI practices, fairness-aware ML, secure ML development |
+| AI system operators | Understanding AI system limitations, human oversight procedures, incident detection |
+| Compliance/risk staff | AIMS clause requirements, AISIA methodology, AI risk assessment |
+| Procurement | AI-specific supplier due diligence, contractual AI requirements |
+| All staff | AI acceptable use policy, what AI is being used for, how to report AI concerns |
+
+**Required outputs:** Competence matrix, training records, training effectiveness evaluations.
+
+### 7.3 Awareness
+**Requirement:** All persons working under the organisation's authority must be aware of: the AI policy, their contribution to AIMS effectiveness, consequences of non-conformance.
+
+### 7.4 Communication
+**Requirement:** Determine internal and external communications relevant to AIMS: what to communicate, when, to whom, how.
+
+**AI-specific communications:**
+- External: transparency disclosures to AI-affected individuals (links to A.8.2 and A.8.5)
+- Internal: AI incident alerts, policy updates, training announcements
+- Regulatory: AI incident notifications where required
+
+### 7.5 Documented Information
+**Requirement:** Maintain and retain documented information required by ISO 42001, plus any the organisation determines necessary for AIMS effectiveness.
+
+**Mandatory documented information (retain):**
+- AIMS scope document
+- AI policy
+- AI risk assessment records
+- AISIA records
+- SoA
+- AI objectives
+- Internal audit reports and results
+- Management review records
+- Nonconformities and corrective actions
+
+---
+
+## Clause 8 — Operation
+
+### 8.1 Operational Planning and Control
+**Requirement:** Plan, implement, and control processes to meet AIMS requirements; implement control plans; manage planned changes; address unintended changes.
+
+**Key operational controls:**
+- AI system development follows documented lifecycle (A.6)
+- Data governance controls applied (A.7)
+- Impact assessments completed before deployment
+- Change management process for AI systems — reassess risk/impact when systems change
+
+### 8.2 AI Risk Assessment
+**Requirement:** Execute AI risk assessments per the method established in 6.1.2. Retain documented results.
+
+### 8.3 AI Risk Treatment
+**Requirement:** Implement the risk treatment plan. Retain documented evidence of treatment.
+
+---
+
+## Clause 9 — Performance Evaluation
+
+### 9.1 Monitoring, Measurement, Analysis and Evaluation
+**Requirement:** Monitor and measure AI system performance, AIMS process effectiveness, and progress against AI objectives.
+
+**Metrics to consider:**
+- AI system performance metrics (accuracy, precision/recall, bias scores) vs defined thresholds
+- AISIA completion rate across in-scope AI systems
+- AI incident count, severity, and MTTR
+- SoA control implementation progress
+- Training completion rates
+- Supplier AI assessment completion rates
+
+**Required outputs:** Monitoring reports, dashboard or metrics register.
+
+### 9.2 Internal Audit
+**Requirement:** Conduct internal audits at planned intervals to determine AIMS conformance and effective implementation.
+
+**Audit programme requirements:**
+- Audit frequency defined (typically annual minimum)
+- Auditor competence and independence — cannot audit own work
+- Audit plan covering all AIMS clauses and applicable controls over the audit cycle
+- Audit reports with findings, nonconformities, and opportunities for improvement
+- Audit records retained
+
+### 9.3 Management Review
+**Requirement:** Top management reviews the AIMS at planned intervals.
+
+**Management review agenda must cover:**
+- Status of actions from previous reviews
+- Changes in external/internal issues affecting the AIMS
+- AI risk and impact assessment results
+- Performance and metrics against AI objectives
+- Internal audit results
+- Nonconformities and corrective actions
+- Opportunities for improvement
+
+**Required outputs:** Management review minutes with decisions and action items.
+
+---
+
+## Clause 10 — Improvement
+
+### 10.1 Continual Improvement
+**Requirement:** Continually improve the suitability, adequacy, and effectiveness of the AIMS.
+
+### 10.2 Nonconformity and Corrective Action
+**Requirement:** When a nonconformity occurs: react, control, evaluate root cause, implement corrective action, review effectiveness.
+
+**AI-specific nonconformity examples:**
+- AI system deployed without completed AISIA
+- Training data bias testing skipped for a model
+- AI incident not reported within required timeframe
+- Staff using public AI tools without following acceptable use policy
+- Supplier AI assessment overdue
+
+**Required outputs:** Nonconformity records, corrective action log with root cause, action taken, and effectiveness review.