Map impacts and set lifecycle monitoring and response: What should it do before continuing use?
Internal development does not remove the need to map impacts, manage dependencies, and monitor continuous screening.
The question
An employer builds its own applicant-screening model using external training data and runs it continuously. Development ownership is documented, but applicant impacts, data dependencies, and post-deployment controls are not. What should it do before continuing use?
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- Limit governance review to internal model development.Internal development is only one part of the lifecycle; it does not address external data, applicant impacts, or continuous operation.
- Review the data source, but leave continuous-use oversight to recruiting.Source review is relevant, but informal handoff to recruiting does not define monitoring, response, or reassessment responsibilities.
- Apply supplier assurance only to the external data provider and model code.Supplier and code checks can provide evidence, but they do not replace assessment of applicant impacts or controls for actual use.
- Map impacts and set lifecycle monitoring and response controls. ✓This addresses the missing context, affected applicants, ongoing monitoring, and response processes while recognizing the external data dependency.
The trap
Separate who built the model from what the deployed system affects and which dependencies it uses. How to remember it
Internal development does not remove the need to map impacts, manage dependencies, and monitor continuous screening.
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