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Under Attack

ISO 42001

AI Management System

The assessment does not stop at checking whether a policy or document exists. Controls are assessed across five stages — from design intent through to demonstrated effectiveness — so the outcome distinguishes “we have a policy” from “we have an operating control that can be demonstrated”.

Methodology

  1. 01

    Identify AI

    Establish where AI is used across the organisation.

  2. 02

    Classify Use Cases

    Classify the identified AI use cases.

  3. 03

    Assess Risk

    Assess the risk attaching to each classified use case.

  4. 04

    Define Controls

    Define the controls the assessed risk calls for.

  5. 05

    Implement Governance

    Put the governance for those controls in place.

  6. 06

    Validate

    Confirm the controls operate as defined.

  7. 07

    Monitor

    Keep the management system under review.

Approach to testing

  • Requirement — what does the applicable standard, regulation or framework require?
  • Control — what control has the organisation established?
  • Implementation — how is the control actually implemented?
  • Evidence — what evidence demonstrates that the control operates?
  • Risk — what happens if the control is ineffective or absent?
  • Action — what needs to be changed?
  • Validation — has the corrective action actually addressed the issue?

Types of assessment

Black-Box

Assessment begins with limited organisational information, to provide an independent perspective of the governance environment.

Grey-Box

Selected organisational documentation, process information and evidence are provided for structured assessment.

White-Box

Full documentation, evidence, stakeholder and process access is provided for detailed control validation.

Hybrid

Combines independent assessment techniques with detailed evidence and stakeholder validation.

Frameworks and standards

ISO/IEC 42001
The AI management system standard the governance is built to.
AI Governance Control Framework
The control framework applied against it.
AI Risk Assessment Toolkit
Applied to each classified use case.
AI System / Use-Case Inventory
The inventory the assessment runs from.
AI Governance Policy Toolkit
Policy set for the management system.

Tools used

Tooling is where testing starts, not where it ends. Every automated result is reproduced by hand before it reaches a report.

AI Governance Toolkit

AI inventory, AI risk assessment, AI governance, AI policy, AI vendor assessment and AI control assessment.

AI System / Use-Case Inventory

Establishes what is in scope before any control is chosen.

PlyoGRC

Where appropriate, the toolkits are supported through PlyoGRC for control, evidence, risk and compliance management.

Checklist approach

The checklist is the floor, not the ceiling. It guarantees coverage so nothing standard is missed; the findings that matter usually come from what a tester does after it is complete.

Foundation

  • AI governance framework
  • AI system inventory
  • AI use-case classification

Risk and policy

  • AI risk assessment
  • AI policies
  • AI roles and responsibilities

Lifecycle and third parties

  • AI lifecycle governance
  • AI vendor governance
  • Human oversight

Operation and assurance

  • AI incident governance
  • AI control implementation
  • AI management review
  • AIMS readiness

How CSS tests

A unified swarm of agents, for blind spot detection

AI agents drive several testing tracks against the same target at once, then cross-check each other. A single tester works one hypothesis at a time; parallel agents cover the space a sequential pass leaves behind.

  • Framework Mapping Agent — maps requirements and controls across applicable frameworks.

  • Policy Analysis Agent — identifies potential missing, inconsistent or outdated requirements.

  • Evidence Analysis Agent — associates evidence with applicable controls and identifies evidence gaps.

  • Risk Analysis Agent — identifies recurring risk themes and potential control weaknesses.

  • Blind-Spot Detection Agent — looks for issues that may not be immediately visible through conventional checklist assessment.

  • Executive Reporting Agent — helps transform detailed assessment information into concise management reporting.

AI-assisted analysis supports the assessment team but does not replace professional judgement. Material findings, risk conclusions and recommendations are reviewed and validated by CyberSmithSECURE professionals.

Why this differs

What CSS does that most vendors do not

Every one of these is checkable. Ask any vendor for the same and compare the answers.

Beyond the checklist

Structured checklists and framework mappings establish coverage, but the assessment continues through implementation, evidence, risk, action and validation.

Operating control, not documentation only

Evidence is validated across five stages: Designed — is it appropriately designed? Implemented — has it been implemented? Operating — is it actually performed? Evidenced — can operation be shown? Effective — is it achieving its goal?

Depth selected per engagement

Black-box, grey-box, white-box or hybrid, chosen on the purpose, scope and risk of the engagement rather than applied uniformly.

Human-in-the-loop AI assistance

AI-assisted analysis supports the assessment team but does not replace professional judgement. Material findings, risk conclusions and recommendations are reviewed and validated by CyberSmithSECURE professionals.

What you receive

A working management system, not a folder of documents

The target state is that owners know what they must do, management knows what decisions are pending, and evidence exists to demonstrate that controls operate. Outputs are grouped by who uses them.

Executive layer

Scope, risk posture, roadmap, management decisions, KPI/KRI, readiness summary

GRC layer

Risk register, Statement of Applicability, policies, procedures, ownership, evidence map, action tracker

Assurance layer

Internal audit, findings, CAPA, management review, certification-readiness assessment

Operational layer

Control records, recurring reviews, awareness, supplier / access / incident / continuity evidence as applicable

Governance cadence established

Monthly
Risk / action review, evidence status, control exceptions, material incidents
Quarterly
Risk trend, supplier / control reviews, KPI/KRI, management action tracking
Annual
Internal audit programme, management review, ISMS objectives, risk refresh, improvement plan

For this engagement specifically

  • Control owners
  • IT teams
  • Security teams
  • Compliance teams
  • Process owners
  • Auditors
  • Key risks
  • Significant gaps
  • Business impact
  • Priority actions
  • Ownership
  • Target timelines

Next

Scope this assessment

Most scopes are settled in one call. Tell us what the application does and who uses it, and we will tell you what testing it properly involves.