Assess whether a shadow system must be decommissioned this quarter (a51d84)
August 31, 2026 · SmartSolo
Situation
A university licensing an AI proctoring vendor cannot treat a DPA inquiry about training on European user data as color commentary on training-data provenance questionnaire. EU AI Act implementation manager must close a shadow system must from that extract under AI Governance / Inventory and Regulatory Fit.
Decision
EU AI Act implementation manager in a university licensing an AI proctoring vendor must choose Policy or governance breach / Model defect / Dual failure / Hold for the missing fact using training-data provenance questionnaire after a DPA inquiry about training on European user data.
Hypotheses to test
- Training-data provenance questionnaire reads as Policy or governance breach once a DPA inquiry about training on European user data is lined up to the same AI Governance population.
- Training-data provenance questionnaire is closer to Model defect after a DPA inquiry about training on European user data; Policy or governance breach would over-claim this Inventory and Regulatory Fit extract.
- Dual failure is still live in training-data provenance questionnaire for EU AI Act implementation manager in a university licensing an AI proctoring vendor.
- Training-data provenance questionnaire is missing the fact EU AI Act implementation manager needs after a DPA inquiry about training on European user data; stop this AI Governance close.
Analysis required
- Check intended purpose and inventory status against EU AI Act / exam-readiness language after a DPA inquiry about training on European user data.
- Map the approved-use case to the system a shadow system must would bind.
- Check intended purpose and inventory status against EU AI Act / exam-readiness language after a DPA inquiry about training on European user data.
- For this AI Governance Inventory and Regulatory Fit file, read training-data provenance questionnaire against a DPA inquiry about training on European user data and write the one fact that would move a shadow system must for EU AI Act implementation manager.
Recommendation
Choose Policy or governance breach / Model defect / Dual failure / Hold for the missing fact on this AI Governance / Inventory and Regulatory Fit packet (training-data provenance questionnaire after a DPA inquiry about training on European user data). The follow-on Inventory and Regulatory Fit action is what EU AI Act implementation manager does next: implement the option, assign an owner, and log the missing fact.
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