Sovereign audit pack — verbatim framework text, control-by-control mapping, evidence index.

AICPA Trust Services Criteria 2017 (with 2022 revisions): "The Trust Services Criteria are used by service auditors to evaluate the design (type 1) and operating effectiveness (type 2) of controls relevant to the following categories: Security, Availability, Processing Integrity, Confidentiality, Privacy. The 2022 revisions incorporate the 2017 COSO framework (Internal Control — Integrated Framework) and include updated criteria for risk assessment, monitoring activities, and information & communication."

TSC CC1.1 (Control environment): "The entity demonstrates a commitment to integrity and ethical values."

TSC CC6.1 (Logical and physical access): "The entity implements logical access security software, infrastructure, and architectures over protected information assets to protect them from security events to meet the entity's objectives."

TSC CC7.2 (System monitoring): "The entity monitors system components and the operation of those components for anomalies that are indicative of malicious acts, natural disasters, and errors affecting the entity's ability to meet its objectives; anomalies are analyzed to determine whether they represent security events."

TSC A1.2 (Availability commitments): "The entity authorizes, designs, develops or acquires, implements, operates, approves, maintains, and monitors environmental protections, software, data backup processes, and recovery infrastructure to meet its objectives."

TSC P4.1 (Privacy collection): "The entity provides notice to data subjects about its privacy practices to meet the entity's objectives related to privacy."

TSC C1.1 (Confidentiality commitments): "The entity identifies and maintains confidential information to meet the entity's objectives related to confidentiality."

ISO/IEC 27001:2022 Clause 4 (Context of the organization): "The organization shall determine external and internal issues that are relevant to its purpose and that affect its ability to achieve the intended outcome(s) of its information security management system."

ISO/IEC 27001:2022 Clause 6.1.2 (Information security risk assessment): "The organization shall define and apply an information security risk assessment process that: (a) establishes and maintains information security risk criteria that include the risk acceptance criteria and criteria for performing information security risk assessments; (b) ensures that repeated information security risk assessments produce consistent, valid and comparable results; (c) identifies the information security risks: (1) apply the information security risk assessment process to identify risks associated with the loss of confidentiality, integrity and availability for information within the scope of the information security management system; (2) assess the consequences and the likelihood and the levels of risk; (d) compares the results of risk analysis with the established risk criteria and prioritises the analysed risks for treatment."

ISO/IEC 27001:2022 Clause 6.1.3 (Risk treatment): "The organization shall define and apply an information security risk treatment process to: (a) select appropriate information security risk treatment options, taking account of the risk assessment results; (b) determine all controls that are necessary to implement the information security risk treatment options chosen; (c) compare the controls determined in (b) above with those in Annex A and verify that no necessary control has been omitted; (d) produce a Statement of Applicability that contains the necessary controls (see 6.1.3 d) and justification for their inclusion, whether they are implemented or not, and the justification for excluding any Annex A control."

ISO/IEC 27001:2022 Annex A Control A.5.1 (Policies for information security): "Information security policy and topic-specific policies shall be defined, approved by management, published, communicated to and acknowledged by relevant personnel and relevant interested parties, and reviewed at planned intervals and if significant changes occur."

ISO/IEC 27001:2022 Annex A Control A.8.5 (Secure authentication): "Secure authentication technologies and procedures shall be implemented based on information access restrictions and the topic-specific policy on access control."

ISO/IEC 27001:2022 Annex A Control A.8.24 (Use of cryptography): "Rules for the effective use of cryptography, including cryptographic key management, shall be defined and implemented."

ISO/IEC 42001:2023 Clause 5.2 (Policy): "Top management shall establish an AI policy that: (a) is appropriate to the purpose of the organization; (b) provides a framework for setting AI objectives; (c) includes a commitment to satisfy applicable requirements; (d) includes a commitment to continual improvement of the AIMS."

ISO/IEC 42001:2023 Clause 6.1.2 (AI risk assessment): "The organization shall define and apply an AI risk assessment process that: (a) establishes and maintains AI risk criteria that include AI risk acceptance criteria and criteria for assessing AI risk; (b) identifies the AI risks considering the AI system lifecycle stages, AI actors, and the categories of harm (e.g. safety, financial, societal, environmental); (c) analyses, evaluates and prioritises the identified AI risks."

ISO/IEC 42001:2023 Annex A Control A.5.2 (AI roles and responsibilities): "Roles and responsibilities for AI shall be defined and allocated, including for the responsible AI officer, AI risk owner, AI quality assurance, and AI system operators."

ISO/IEC 42001:2023 Annex A Control A.6.1.2 (Data for AI systems): "The organization shall define and implement processes for the responsible management of data used to develop, train, validate, deploy, and operate AI systems, including data quality, data provenance, data minimisation, and bias mitigation."

ISO/IEC 42001:2023 Annex A Control A.6.2.4 (AI system verification and validation): "The organization shall define and implement processes for the verification and validation of AI systems, including performance testing, robustness testing, bias testing, and human oversight verification."

ISO/IEC 42001:2023 Annex A Control A.8.4 (AI system impact assessment): "The organization shall perform AI system impact assessments to identify and document the potential consequences of the AI system on individuals, groups, communities, and society."

EU AI Act, Article 3(1) (Definitions — AI system): "'AI system' means a machine-based system that is designed to operate with varying levels of autonomy and that may exhibit adaptiveness after deployment, and that, for explicit or implicit objectives, infers, from the input it receives, how to generate outputs such as predictions, recommendations, or decisions, that can influence physical or virtual environments."

EU AI Act, Article 5 (Prohibited practices): "The following AI practices shall be prohibited: (a) the placing on the market, putting into service, or use of an AI system that deploys subliminal techniques beyond a person's consciousness or purposefully manipulative or deceptive techniques, with the objective, or the effect, of materially distorting the behaviour of a person or a group of persons by appreciably impairing their ability to make an informed decision, thereby causing them to take a decision they would not have otherwise taken in a way that causes or is likely to cause them, another person or group of persons significant harm; (b) the placing on the market, putting into service, or use of an AI system that exploits any of the vulnerabilities of a person or a group of persons due to their age, disability or a specific social or economic situation, with the objective, or the effect, of materially distorting the behaviour of that person or group of persons..."

EU AI Act, Article 9 (Risk management system): "A high-risk AI system shall have a risk management system that is implemented as a continuous, iterative process planned and run throughout the entire lifecycle of the high-risk AI system. The risk management system shall consist of the following steps: (a) the identification and analysis of the known and reasonably foreseeable risks to health, safety or fundamental rights; (b) the estimation and evaluation of the risks that may emerge when the high-risk AI system is used in accordance with its intended purpose, and under conditions of reasonably foreseeable misuse; (c) the evaluation of other risks that may emerge, based on the analysis of data gathered from the post-market monitoring system; (d) the adoption of appropriate and targeted risk management measures designed to address the risks identified pursuant to points (a), (b) and (c)."

EU AI Act, Article 14 (Human oversight): "High-risk AI systems shall be designed and developed in such a way, including with appropriate human-machine interface tools, that they can be effectively overseen by natural persons during the period in which they are in use. Natural persons assigned to ensure human oversight shall have the necessary competence, training, and authority. The oversight measures shall ensure that those persons can do, as appropriate, the following: (a) properly understand the relevant capacities and limitations of the high-risk AI system; (b) remain aware of the tendency to automatically rely on or over-rely on the output produced by a high-risk AI system (automation bias); (c) correctly interpret the high-risk AI system's output; (d) decide not to use the high-risk AI system or disregard, override or reverse the output of the high-risk AI system; (e) intervene on the operation of the high-risk AI system or interrupt the system through a 'stop' button or a similar procedure."

EU AI Act, Article 50 (Transparency obligations for providers and deployers of certain AI systems): "Providers shall ensure that AI systems intended to interact directly with natural persons are designed and developed in such a way that the natural persons concerned are informed that they are interacting with an AI system, unless this is obvious to a reasonably well-informed natural person. Providers of generative AI systems shall ensure that outputs of the AI system are marked in a machine-readable way and detectable as artificially generated or manipulated, including by watermarking and metadata techniques."

EU AI Act, Article 50(2): "Deployers of an emotion recognition system or a biometric categorisation system shall inform the natural persons exposed thereto of the operation of the system, and shall process the personal data in accordance with Regulation (EU) 2016/679 [GDPR], Regulation (EU) 2018/1725 [EUDPR], and Directive (EU) 2016/680 [LED]."

EU AI Act, Article 55 (Post-market monitoring): "Providers of high-risk AI systems shall establish and document a post-market monitoring system in a manner that is proportionate to the nature of the AI system. The post-market monitoring system shall be used to: (a) ensure continuous and systematic collection, documentation and analysis of data on the performance of high-risk AI systems throughout their lifetime; (b) identify any need to apply immediately any corrective or preventive measures; (c) feed into the process of updating the relevant technical documentation; (d) inform the design and development process of future AI systems."

UK GDPR, Article 5(1) (Principles relating to processing of personal data): "Personal data shall be: (a) processed lawfully, fairly and transparently in relation to the data subject ('lawfulness, fairness and transparency'); (b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes ('purpose limitation'); (c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed ('data minimisation'); (d) accurate and, where necessary, kept up to date ('accuracy'); (e) kept in a manner which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed ('storage limitation'); (f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures ('integrity and confidentiality')."

UK GDPR, Article 5(2) (Accountability): "The controller shall be responsible for, and able to demonstrate compliance with, paragraph 1 ('accountability')."

UK GDPR, Article 6 (Lawfulness of processing): "Processing shall be lawful only if and to the extent that at least one of the following applies: (a) the data subject has given consent to the processing of his or her personal data for one or more specific purposes; (b) processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract; (c) processing is necessary for compliance with a legal obligation to which the controller is subject; (d) processing is necessary in order to protect the vital interests of the data subject or of another natural person; (e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; (f) processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests, rights or freedoms of the data subject which require protection of personal data, in particular where the data subject is a child."

UK GDPR, Article 28 (Processor): "The processing by a processor shall be governed by a contract or other legal act under Union or Member State law, that is binding on the processor with regard to the controller and that sets out the subject-matter and duration of the processing, the nature and purpose, the type of personal data, the categories of data subjects, and the obligations and rights of the controller. That contract or other legal act shall stipulate, in particular, that the processor: (a) processes the personal data only on documented instructions from the controller, including for transfers of personal data to a third country or an international organisation, unless required to do so by Union or Member State law to which the processor is subject; (b) ensures that persons authorised to process the personal data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality; (c) implements appropriate technical and organisational measures to ensure a level of security appropriate to the risk; (d) engages another processor only with the prior specific or general written authorisation of the controller..."

UK GDPR, Article 32 (Security of processing): "Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing, as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, the controller and the processor shall implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including, inter alia, as appropriate: (a) the pseudonymisation and encryption of personal data; (b) the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services; (c) the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident; (d) a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing."

UK GDPR, Article 33 (Notification of a personal data breach to the ICO): "In the case of a personal data breach, the controller shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the Information Commissioner, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons."

UK GDPR, Article 35 (Data protection impact assessment): "Where a type of processing is likely to result in a high risk to the rights and freedoms of natural persons, the controller shall, prior to processing, carry out an assessment of the impact of the envisaged processing operations on the protection of personal data."

Data Protection Act 2018, Schedule 1, Part 1, Para.5 (Substantial public interest — safeguarding of children and individuals at risk): "This condition is met if the processing — (a) is necessary for the purposes of (i) the protection of children and individuals at risk; (ii) the assessment or removal of the need for support or services; (iii) the provision of support or services to children and individuals at risk or who have particular needs; and (b) is of a specified category of personal data, and the processing is necessary for reasons of substantial public interest."

Data Protection Act 2018, Schedule 1, Part 2, Para.10 (Substantial public interest — preventing or detecting unlawful acts, etc.): "This condition is met if the processing is necessary for the purposes of preventing or detecting unlawful acts, or for the purposes of safeguarding the economic well-being of the UK or a part of the UK."