Purpose
Centralize documentation and traceability requirements for AI systems so audits, regulatory inspections, and customer reviews can be satisfied quickly.
Scope
Covers technical documentation, risk assessments, validation reports, monitoring logs, and stakeholder communications for all regulated or high-risk AI systems.
- EU AI Act high-risk systems
- ISO 42001 AI Management System scope
- Customer-facing AI requiring transparency disclosures
Definitions
- Traceability Matrix: Mapping between requirements, controls, evidence, and owners.
- Immutable Storage Plan: Strategy ensuring documents cannot be altered without audit trails.
- Documentation Lead: Role responsible for maintaining templates and conducting audits.
Policy
Documentation must be accurate, current, and stored in immutable repositories with access controls. Traceability across design, validation, deployment, and monitoring artifacts must be maintained. Audit requests must be fulfilled within agreed timelines.
Roles and Responsibilities
Documentation Lead curates templates and executes audits. Control owners upload evidence. Compliance reviews documentation for regulatory submissions. Security enforces repository access and immutability.
Procedures
Documentation lifecycle includes:
- Define evidence templates for risk assessments, validation, monitoring, and incident logs.
- Link evidence to traceability matrix entries with versioning metadata.
- Store documents in immutable repository (e.g., WORM storage, signed artifacts).
- Run quarterly documentation health checks and remediate gaps.
- Provide read-only access for auditors/customers under NDA.
Exceptions
Temporary storage in non-immutable locations is allowed only during drafting; final versions must be uploaded before go-live.
Review Cadence
Documentation completeness reports are reviewed quarterly; major system changes trigger immediate updates.
References
- EU AI Act Article 11 (Technical documentation)
- ISO/IEC 42001:2023 Clause 7 (Support)
- Internal documents: Documentation Playbook, Traceability Matrix Template, Evidence Storage SOP