Trigger review for material use or data changes: What should | AIGP
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Trigger review for material use or data changes: What should policy governance require?

AIGP Understanding the Foundations of AI Governance Medium

Material changes in product scope and applicant data should trigger review before the next scheduled cycle.

The question

An insurer reviews its AI policy every year. Six months after the last review, it expands an underwriting model from one product line to several and adds a new applicant data source. No review trigger addresses material use or data changes. What should policy governance require?

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  1. Keep the annual review cycle and record the expansion there.
    Waiting until the annual cycle delays governance review despite material changes affecting use and data suitability.
  2. Review only if underwriting accuracy declines materially.
    Governance changes can create risks without immediate accuracy decline, including provenance, population, and control limitations.
  3. Trigger review for material use or data changes. ✓
    Expansion of use and addition of data can alter risks, suitability, accountability, and controls before the scheduled annual review.
  4. Ask the vendor whether the existing model remains unchanged.
    Model sameness would not resolve changed product scope or applicant data, which independently create governance review needs.
The trap
Look beyond model-version changes; altered populations, purposes, or data sources can independently require review.

How to remember it

Material changes in product scope and applicant data should trigger review before the next scheduled cycle.

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