Assess whether training data has a lawful basis and documented lineage
August 31, 2026
SITUATION Board AI liaison in a retailer using generative AI in customer service has one working extract — EU AI Act high-risk classification worksheet — after a near-miss where an agent emailed a customer unreviewed. If EU AI Act high-risk classification worksheet cannot support training data has a, the only defensible AI Governance output is hold.
DECISION Board AI liaison in a retailer using generative AI in customer service must choose Policy or governance breach / Model defect / Dual failure / Hold for the missing fact using EU AI Act high-risk classification worksheet after a near-miss where an agent emailed a customer unreviewed.
HYPOTHESES TO TEST 1. Authorize Policy or governance breach now; EU AI Act high-risk classification worksheet already has the discriminator after a near-miss where an agent emailed a customer unreviewed. 2. Keep Model defect in force until EU AI Act high-risk classification worksheet is completed after a near-miss where an agent emailed a customer unreviewed for board AI liaison. 3. Treat EU AI Act high-risk classification worksheet as Dual failure because both readings appear after a near-miss where an agent emailed a customer unreviewed. 4. Refuse a AI Governance close: board AI liaison does not have the decision training data has a turns on in EU AI Act high-risk classification worksheet.
ANALYSIS REQUIRED 1. Reproduce the incident row in EU AI Act high-risk classification worksheet and say whether it ever touched production data. 2. Split policy-or-governance failure from a model defect using prompts, outputs, and human edits in EU AI Act high-risk classification worksheet. 3. Reproduce the incident row in EU AI Act high-risk classification worksheet and say whether it ever touched production data. 4. For this AI Governance Policy and Oversight file, read EU AI Act high-risk classification worksheet against a near-miss where an agent emailed a customer unreviewed and write the one fact that would move training data has a for board AI liaison.
RECOMMENDATION Choose Policy or governance breach / Model defect / Dual failure / Hold for the missing fact on this AI Governance / Policy and Oversight packet (EU AI Act high-risk classification worksheet after a near-miss where an agent emailed a customer unreviewed). The follow-on Policy and Oversight action is what board AI liaison does next: implement the option, assign an owner, and log the missing fact.
COMMAND RETURNS - Bottom-line AI Governance option on training data has a, then the evidence in EU AI Act high-risk classification worksheet, then the action for board AI liaison - Hypothesis scorecard against EU AI Act high-risk classification worksheet: supported / rejected / untestable - Regulatory or exam hook Policy and Oversight would cite - Policy and Oversight finding in EU AI Act high-risk classification worksheet that a second reviewer can re-perform
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