ISO/IEC 42001:2023·Annex A A.7.3·high·Component: Technological controls

What this control requires

Data acquisition for AI use shall be governed through defined criteria, approvals, and third-party due diligence where applicable.
— ISO/IEC 42001:2023, Annex A A.7.3

In plain English

Data acquisition for AI use shall be governed through defined criteria, approvals, and third-party due diligence where applicable. In practice, this means you can prove you define 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.

This control is rated high. Auditors expect a named owner, a remediation SLA, and a tooling artefact that evidences continuous operation.

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 Technological controls, the assessor will trace your implementation back to the catalogue reference (Annex A A.7.3) and look for objective evidence on the latest two assessment cycles.

How to implement

  1. Write a short policy stating intent, scope and named owner.
  2. Encode it as a platform guardrail — SCP, Azure Policy initiative, Organisation Policy, or repository policy.
  3. Wire a monitoring signal that catches drift (CSPM rule, SIEM rule, scheduled query, Workspace alert) and ticket it.
  4. Review on a documented cadence and capture the review in the risk register or compliance tracker.

Operational checklist

  • Define. Document the trigger, the owner and the cadence.
  • Govern. Document the trigger, the owner and the cadence.
  • Use. Document the trigger, the owner and the cadence.
  • Scope: data.

Evidence to collect

  • Policy Document. A signed and version-controlled policy / standard / procedure document.
  • Vendor Risk Management. vendor_risk_management evidence

Policies and vendor risk evidence should demonstrate defined criteria, approvals, and due diligence for data acquisition used in AI systems. Focus: Acquisition of data.

Related controls in ISO/IEC 42001:2023

References

Topics: data governancevendor riskdata acquisitionvendor managementdata lifecycle management