Northbridge Mutual’s claims division wants to deploy a generative AI copilot to summarize adjuster notes. Before approving it, the governance team must establish who owns the use case, what data it may handle, which risks need treatment, and what evidence supports the decision. We will build the operating shape for a program that turns AI adoption requests into traceable decisions, controls, and board reporting.
An AI inventory records every AI system and use case, its owner, purpose, data, supplier, and risk tier. An AI risk register records each identified risk, its owner, rating, treatment, and review date. Together, these artifacts make the program visible and give reviewers a reliable starting point. Northbridge Mutual’s operating model connects intake, classification, control, monitoring, and reporting:
A defensible program shows who had authority to approve, challenge, or stop a decision, and retains the evidence behind that decision. Decision rights assign those authorities across business owners, risk and compliance, security, legal, procurement, and senior leadership. They prevent an approval from becoming an informal email thread with no accountable owner.
The program also needs enforcement. The AI governance lead checks inventory completeness and overdue reviews on the organization’s chosen cadence. Control owners provide evidence. A violation triggers investigation, corrective action, and, where warranted, suspension of the affected use case. An exception records the business reason, risk acceptance authority, expiry date, and conditions for continued use.
Evidence matters A policy becomes governance only when assigned owners check it, record results, and act on violations.
Change control keeps the record current when a system’s purpose, data sources, supplier, model, or affected population changes. This aligns with the NIST AI Risk Management Framework (NIST AI RMF), whose Govern function covers accountability and organizational policies, while Map, Measure, and Manage connect those decisions to identified risks and treatments.
A program works as a recurring operational cycle, not a one-time approval gate. The first line, the business team operating the use case, owns safe use and evidence. The second line sets policy, challenges risk decisions, and monitors compliance. The third line provides independent assurance through internal audit. Escalation reaches senior leadership when residual risk, repeated noncompliance, or a material change exceeds delegated authority.
Northbridge Mutual can use a monthly cycle to maintain its records and expose gaps before they become audit findings. We can trace how each activity supports the next decision: