Document monitoring: What governance action is best supported?
The provider-deployer arrangement needs documented monitoring, escalation, and intervention authority.
The question
A university in the EU deploys a vendor-operated admissions-support system classified as high-risk under the EU AI Act. The vendor is the provider and controls model updates; the university is the deployer and controls applicant workflows and complaints. Their contract does not document monitoring, escalation, or authority to suspend use. What governance action is best supported?
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- Assign complaints to the university and updates to the vendor.This division covers two activities but does not define shared monitoring, incident escalation, or who can intervene when use becomes unsafe or noncompliant.
- Have the vendor monitor model updates.This assigns one technical task but leaves workflow impacts, complaints, escalation, and suspension authority unresolved.
- Rely on the vendor's conformity documentation.Provider documentation is evidence within its scope; it does not replace deployment-specific monitoring, responsibility allocation, or suspension authority.
- Document monitoring, escalation, and suspension authority. ✓The provider and deployer control different parts of a high-risk deployment, so their arrangements should assign monitoring, incident escalation, and competent intervention authority across those responsibilities.
The trap
Map responsibilities to control of updates, deployment context, impact evidence, escalation, and intervention. How to remember it
The provider-deployer arrangement needs documented monitoring, escalation, and intervention authority.
How many of these would you get right?
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