Lesson · 8 min · Stage 1

Building a governance program

Learning goal: Start and grow a program with clear decision rights.

For reference purposes only. Not legal advice.

Draft: not yet fact-checked or legally reviewed

SimplifiedPractical guidance drawn from supplied study notes. It is not specific to any law. Adapt it to your size and sector.

Key points

  • Start with one accountable owner, a short policy and a register of systems.
  • A RACI matrix makes decision rights explicit. Every activity needs exactly one Accountable person.
  • Separate the charter (what and why) from the operating model (how).
  • Four clusters of work: executive oversight, model ownership, audit and compliance, and operational support.
  • Propose changes to a steering group as findings, implications, recommended change and rationale.

Who this is for: anyone new to the topic. Related stage: Set up governance.

Start small, then grow

A new program does not need a large committee. It needs a named owner, a short policy people can follow, and a list of the AI systems already in use. Grow from there as risk and scale grow (see the lifecycle).

RACI: who decides, who does

A RACI matrix assigns four roles to each activity:

  • Responsible: does the work. More than one person can be Responsible.
  • Accountable: answers for the result, holds final approval and veto. There must be exactly one.
  • Consulted: gives input before a decision.
  • Informed: is told afterwards.

Three common mistakes: no Accountable person (nobody owns production monitoring, so blame moves between teams); two Accountable people for one approval (deadlock); and “Consulted” on everything (legal must review every tiny prompt tweak, so engineering stalls).

Four clusters of work

Governance work falls into four clusters, along two axes: strategy vs day-to-day, and business accountability vs independent assurance.

Focus Business accountability Independent assurance
High-level strategy Executive oversight: steering group, risk appetite, principles Audit and compliance: legal, privacy, security, risk, internal audit
Day-to-day work Model ownership: product lead accountable for a model’s performance, value and impact Operational support: data science, ML operations, engineering

Charter and operating model

The charter states purpose, authority, scope, targets, meeting rhythm, quorum and escalation. The operating model says how work flows: teams, decision levels, tooling. Changing a target is a charter amendment. Changing who approves low-risk exceptions is an operating model adjustment.

Taking a change to the steering group

Use four parts: Findings (facts from the data, for example “remediation has slowed 40% this quarter”); Implications (the risk or business impact); Recommended change (and whether it is a charter amendment or an operating model adjustment); Rationale (why this change solves the problem, for example freeing the group’s time for high-risk deployments).

What to do now

  • Download the AI use policy template.
  • Check each activity in your RACI for exactly one Accountable person.
  • Write one page: your charter in five lines.

Sources

  • Supplied governance study notes (module 1)

Reviewed 2 Oct 2026. Sources: NIST AI Risk Management Framework; ISO/IEC 42001 standard page.

Terms used: Accountability, Operating model, RACI.

Part of: Leaders path.

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