Require notice: What control is missing most directly?
A material subprocessor change requires advance notice, impact review, and approval before use.
The question
Under the insurer's global, NIST-aligned internal AI governance policy, EU AI Act obligations that apply are assumed satisfied. A vendor model performs claims triage, and mapping, data-access review, privacy-role analysis, monitoring, incident handling, and deployment approval are complete. The vendor plans to replace a key inference subprocessor. What control is missing most directly?
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- Repeat aggregate accuracy testing and obtain revised contractual warranties.Accuracy testing and warranties can provide useful evidence, but they do not alone require a deployment-specific review of the replacement subprocessor.
- Require notice, impact review, and approval before replacement. ✓Advance notice and a documented impact review allow the insurer to reassess the changed dependency and approve or reject its use before operation.
- Preserve the existing service-level commitments.Service levels address continuity and performance expectations, not changed data access, responsibilities, security, or model behavior.
- Review the next annual vendor report.An annual report may provide assurance evidence, but it does not trigger timely review of an imminent material dependency change.
The trap
For a changed supplier or subprocessor, select the control that requires reassessment before continued use. How to remember it
A material subprocessor change requires advance notice, impact review, and approval before use.
How many of these would you get right?
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