NIST AI RMF

Establish data transfer and storage policy for AI training data. Enforce approved storage locations from point of collection.

Implement DLP controls in the data acquisition environment to prevent unauthorised extraction or transfer of training data.

Enforce data handling policy in the build environment. Require explicit approval for any data transfers outside the environment.

Configure DLP controls in the build environment to block training data from leaving approved boundaries.

Conduct a privacy risk assessment at use case design stage. Determine if a DPIA is required before data acquisition.

Apply S1-defined privacy controls during data acquisition: verify consent, minimise data, anonymise personal data.

Apply anonymisation and masking controls to personal data before use in model training. Validate de-identification effectiveness.

Apply Privacy by Design in model architecture using differential privacy or federated learning where technically feasible.

Publish the privacy notice and confirm consent management is operational before go-live.

Define and sign off a purpose-to-data-source matrix with lawful basis at intake. Make it the approved baseline for runtime enforcement.

Sign zero-retention/no-training terms with each model provider and obtain DPO sign-off on the data flow before enabling any endpoint.

Restrict access to pre-anonymisation personal data to the minimum authorised set. Enforce at point of acquisition.

Apply robust de-identification (k-anonymity, l-diversity, differential privacy) during data processing. Validate effectiveness.

Implement output filters to detect and suppress quasi-identifying attribute combinations in model responses.

Propagate source ACLs and classification labels onto every chunk at ingestion. Reject documents whose entitlements cannot be resolved.

Scan every model response inline with DLP before delivery; redact or block PII, PAN and MNPI matches. Keep the rule set version-controlled.

Define minimum human oversight requirements by risk tier at design stage. Assign named accountability for oversight operations.

Design HITL oversight mechanisms at use case design stage including trigger criteria, review workflow, and escalation paths.

Build and test HITL routing logic and escalation pathways in the AI system. Validate with pilot before deployment.

Operate HITL controls in production and log all interventions and outcomes. Review override patterns quarterly.

Conduct periodic oversight effectiveness reviews. Escalate to governance when oversight metrics fall below threshold.

Define and sign off each agent's delegation envelope — maximum depth and strict scope attenuation — before build begins.

Document each agent's identity, minimum scopes, on-behalf-of population, and delegation depth at design time. Gate build on governance sign-off of the authority matrix.

Mint a unique, attestation-backed workload identity per agent at onboarding. Register every SPIFFE-ID to an owner, use case, and approval ticket; ban shared service accounts.

Implement on-behalf-of token exchange and prove with negative tests that the agent cannot exceed the user's ACL. Gate release on these tests passing.

Register every agent identity with a named human owner, approved use case, scopes, and status before issuance. No registry entry, no identity.

Write authorisation policy as versioned, peer-reviewed code traced to approved scopes. Gate promotion on allow/deny scenario tests passing.

Scan every commit to agent code, prompts, and config for embedded secrets. Block merges on detection and triage findings to closure.

Vet and approve every MCP server and peer agent before registering its identity on the allow-list. Block integration until vetting is signed off.

Mint short-lived, task-scoped tokens just-in-time from a central token service. Enforce a hard max TTL and resource-bound audience so no standing credential exists.

Grant sensitive scopes just-in-time for a bounded window with auto-revocation; require human approval for high-impact elevations. Hold zero standing privilege.

Classify tools by impact and reversibility at design and define which calls require human approval. Obtain governance sign-off on the thresholds before build.

Bind each agent role to an explicit tool allow-list and validate every call against a strict JSON Schema at the orchestrator. Reject unlisted tools and out-of-bounds arguments before dispatch.

Mint short-lived, task-scoped credentials per tool. Block issuance outside the approved scope register and enforce automatic expiry.

Review DLP hits and blocked-egress events, tune detectors, and recertify the destination allow-list periodically. Route new destinations through security change control.

Monitor production for anomalous data transfers in real time. Alert on any transfer outside approved data flow boundaries.

Tag personal data with subject identifiers at ingestion and maintain an artefact inventory map of every store it reaches. Keep lineage current so erasure can propagate.

Conduct periodic privacy vulnerability assessments including re-identification risk testing as new techniques emerge.

Seed registered canary records into the fine-tuning corpus during data preparation. Control the seed manifest so canaries stay traceable and tamper-proof.

Instrument every identity-issuing component with schema-conformant audit emitters. Block release until completeness and tamper-evidence tests pass.

Define per-identity behaviour profiles and thresholds at build. Rehearse automated suspension and sign off measured revocation time before go-live.

Define per-agent behavioural baselines and detection rules during build. Validate against simulated misuse and sign off thresholds before release.

Build signed, append-only tool-call logging into the orchestrator against a defined audit schema. Block release until completeness and tamper-evidence tests pass.

Monitor for privacy incidents in production including personal data appearing in outputs. Notify regulators within required timeframes.

Tag every memory and vector record with subject-id and retention class; partition stores per tenant/user. Prove the erasure and isolation paths in testing before release.

Test de-identification approach against known re-identification attacks (quasi-identifier linkage, singling-out). Remediate if risk is high.

Penetration test AI system data access boundaries (API endpoints, system prompt exposure, memory leakage).

Conduct periodic data leakage audits including training data memorisation testing. Escalate confirmed leakage incidents to PDPA notification process.

Implement tamper-evident capture of prompts, outputs, and version state during build. Verify a full incident timeline can be reconstructed before go-live.

Run agent tool calls in a network-restricted sandbox behind a deny-by-default egress allow-list. Require security approval for any destination added.

Configure monitoring to track oversight process adherence metrics in production (review rate, SLA compliance, override frequency).

Verify each running agent authenticates with its own SVID; revoke on decommission or compromise. Scan periodically for shared or static credentials and remediate.

Reconcile the registry against runtime identities and suspend unregistered principals. Recertify ownership and scopes periodically; decommission retired agents.

Alert on un-revoked elevations and any standing sensitive grant. Report the zero-standing-privilege position to the risk owner on a set cadence.

Sweep runtimes and repos on a schedule for static credentials. Alert on any credential exceeding its maximum age and track findings to closure.

Baseline each agent identity's behaviour and alert on out-of-profile use. Auto-suspend credentials on high-confidence anomalies and track mean-time-to-revoke.

Build sandbox profiles per tool class and run escape and egress tests before release. Treat any containment failure as a blocking defect.

Label tool and external content as tainted and propagate the label through the agent context. Block privileged calls whose parameters derive from tainted outputs and prove it with injection tests before release.

Build credential revocation and dispatch blocking out-of-band of the agent loop. Gate release on an end-to-end kill test meeting the latency target.

Require idempotency keys, dry-run, and rollback on every state-changing tool. Gate onboarding on duplicate-call and rollback tests passing.

Red-team tool-misuse and privilege-escalation paths before release. Gate deployment on remediation or signed risk acceptance of all findings.

Permit outbound tool calls only to allow-listed destinations and DLP-scan arguments and payloads. Block or quarantine calls carrying sensitive data to disallowed sinks.

Enforce hard per-task ceilings on tool calls, spend, and data volume with a circuit breaker that halts the run. Fail closed when any ceiling is hit.

Baseline normal tool-call behaviour per agent and alert on rate, sequence, or argument anomalies. Auto-throttle or quarantine on high-confidence deviations.