A.7.5·high·Component: Technological controlsWhat this control requires
Traceability of data origins and transformations shall be retained for AI datasets to support governance, audits, and investigations.
In plain English
Traceability of data origins and transformations shall be retained for AI datasets to support governance, audits, and investigations. In practice, this means you can prove you govern 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.7.5) and look for objective evidence on the latest two assessment cycles.
How to implement
- Write a short policy stating intent, scope and named owner.
- Encode it as a platform guardrail — SCP, Azure Policy initiative, Organisation Policy, or repository policy.
- Wire a monitoring signal that catches drift (CSPM rule, SIEM rule, scheduled query, Workspace alert) and ticket it.
- Review on a documented cadence and capture the review in the risk register or compliance tracker.
Operational checklist
- Govern. Document the trigger, the owner and the cadence.
- Scope: data, governance.
Evidence to collect
- Policy Document. A signed and version-controlled policy / standard / procedure document.
- Code Repo Scan. Source-control evidence — branch protection, required reviewers, CI status, SCA / SAST reports.
Policies and repository evidence should demonstrate that the origins and transformations of AI datasets remain traceable for governance, audit, and investigation purposes. Focus: Data provenance.
Related controls in ISO/IEC 42001:2023
- Annex A A.6.2.6 — Data provenance
- Annex A A.7.3 — Acquisition of data
- Annex A A.6.2.7 — Preparation of data
- Annex A A.7.6 — Data preparation
- Annex A A.6.2.4 — Data acquisition
- Annex A A.7.2 — Data for development and enhancement of AI systems
References
- ISO/IEC JTC 1/SC 42 — ISO/IEC 42001:2023
- Catalogue identifier:
Annex A A.7.5
Topics: data governancedata provenancetraceabilitydata lifecycle managementaudit evidence