Require notice: What control is missing most directly? | AIGP
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Require notice: What control is missing most directly?

AIGP Understanding How to Govern AI Deployment and Use Medium

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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  1. 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.
  2. 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.
  3. Preserve the existing service-level commitments.
    Service levels address continuity and performance expectations, not changed data access, responsibilities, security, or model behavior.
  4. 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.

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