ISO/IEC 42001:2023·Annex A A.4.3·medium·Component: Organizational controls

What this control requires

Data resources required for AI development, operation, and monitoring shall be identified, managed, and governed.
— ISO/IEC 42001:2023, Annex A A.4.3

In plain English

Data resources required for AI development, operation, and monitoring shall be identified, managed, and governed. In practice, this means you can prove you manage data-level controls on a defined cadence.

Why it matters

ISO 42001 is the first audited evidence regulators, customers and investors can ask for that you are managing AI risk. Each Annex A control is a check-box in that audit; it is also the management system enterprises are starting to require from AI vendors before an MSA can be signed.

What an auditor looks for

An ISO 42001 auditor verifies you have an AI policy, a risk-based system of impact assessments for each AI system, lifecycle controls from data acquisition through retirement, and third-party-AI controls that pierce the vendor's wrapper to underlying model behaviour.

Within Organizational controls, the assessor will trace your implementation back to the catalogue reference (Annex A A.4.3) and look for objective evidence on the latest two assessment cycles.

How to implement

Asset Inventory

AWS. AWS Config Aggregator across every account + region gives a real-time inventory; ship the daily snapshot to S3 and surface drift in Security Hub.

Azure. Azure Resource Graph plus Defender for Cloud's inventory blade enumerates every subscription; export to Log Analytics for retention and Workbooks for reporting.

GCP. Cloud Asset Inventory exports a daily feed of every resource and IAM binding; query via BigQuery and alert on appearance/disappearance.

Endpoints. Pipe MDM telemetry (Intune / Jamf / Workspace ONE) into your CMDB so laptops and phones are inventoried with the same rigour as cloud resources.

Operational checklist

  • Manage. Document the trigger, the owner and the cadence.
  • Monitor. Document the trigger, the owner and the cadence.
  • Develop. Document the trigger, the owner and the cadence.
  • Govern. Document the trigger, the owner and the cadence.
  • Scope: data, resources.

Evidence to collect

  • Policy Document. A signed and version-controlled policy / standard / procedure document.
  • Infra Scan. Continuous infrastructure-posture telemetry — AWS Config, Azure Policy compliance, GCP Organisation Policy, Wiz / Prisma findings.

Policies and inventories should identify data resources used by AI systems, while infrastructure or platform evidence should demonstrate where those resources are stored, processed, and monitored. Focus: Data resources.

Common pitfalls

  • Inventories that exclude SaaS, shadow IT and ephemeral cloud resources (Lambda, Cloud Run, K8s pods) miss the assets where most modern incidents start.

Related controls in ISO/IEC 42001:2023

References

Topics: governance riskdata governanceasset inventorydata lifecycle management