Reporting of concerns

Define and operate a process for people to raise concerns about what the organization does in relation to an AI system at any point in its life cycle. In practice the record is concern reporting procedure with confidential or anonymous options. For reporting of concerns a team name is not a person, so write the name.

What it asks

Define and operate a process for people to raise concerns about what the organization does in relation to an AI system at any point in its life cycle.

Where generative AI changes the answer

A reporting route for concerns has to work for a wrong answer as well as for misconduct, and the person reporting rarely knows which category it is.

Who it binds

Top management and the named AI roles. For A.3.3 the named role is the owner of concern reporting procedure with confidential or anonymous options.

Evidence an auditor normally samples

• Concern reporting procedure with confidential or anonymous options
• Promotion of the channel to staff and contractors
• Investigation and escalation records and response times
• Anti-reprisal protections

The test you can run

Compare concern reporting procedure with confidential or anonymous options with the use as it runs today; the gap between the two is the finding to record.

Common failures

• Channel exists but is unknown to contractors
• No protection from reprisal
• Reports not escalated to management

Before the draft publishes

For A.3.3, name the person who can approve a use, the person who owns the output and the person who can switch the system off. If one name is missing, that is the finding. The first artefact to produce is concern reporting procedure with confidential or anonymous options.

Where this sits against the draft

The draft's published scope names controls for the risks it identifies, and A.3.3 (reporting of concerns) is the published ISO/IEC 42001 control closest to that work. The draft does not replace it, and an audit still tests it against the evidence listed here.