Gapless

Frameworks

The security, privacy, and AI frameworks enterprise customers ask about, what each requires in practice, and the specific engineering controls in this system that satisfy them.

This page summarizes the frameworks most often raised by enterprise customers and internal legal teams, and maps each to concrete controls. Use it to plan work and to speak the same language as compliance teams. It is a summary, not a substitute for the frameworks themselves or for legal advice.

SOC 2

An attestation report by an independent auditor on controls related to security, and optionally availability, confidentiality, processing integrity, and privacy. A Type II report covers how controls operated over a period, usually 6 to 12 months, and is what enterprise customers expect.

Control areaIn this system
Access controlSSO, role-based permissions, access reviews, least privilege for engineers and services
Change managementReviewed pull requests, CI tests and eval gates, controlled deploys
Risk assessmentThreat model, AI risk tiers
MonitoringAlerts, audit logs, incident response
Vendor managementReviews of model providers and other subprocessors
Data protectionEncryption, retention, deletion
AvailabilityBackups, disaster recovery tests, SLOs

AI-specific points auditors increasingly check: how prompt and model changes are controlled (treat them as code changes with review and evaluation), and how model providers are assessed as vendors.

ISO/IEC 27001

An international standard for an information security management system (ISMS), certified by an accredited body. It overlaps heavily with SOC 2, with more emphasis on the management system: documented risk assessment, a statement of applicability for its control set, internal audits, and management review.

If you have SOC 2 controls in place, ISO 27001 is mostly additional documentation and process.

ISO/IEC 42001

A standard for an AI management system, published in 2023. It applies the management system approach to AI: policies, risk and impact assessment, lifecycle controls, data quality, transparency, and oversight, with a set of AI-specific controls.

Requirement areaIn this system
AI policy and rolesIntended and prohibited uses, accountability table
AI risk assessmentRisk tiers for use cases
AI impact assessmentImpact assessments for high-tier use cases
Lifecycle controlsEvaluation datasets, CI gates, canary rollouts, monitoring
Data for AIData inventory, sources, quality checks, lineage
Information for interested partiesTransparency notices, system card
Third-party relationshipsModel provider records and reviews

The Responsible AI and Governance section describes most of what 42001 expects. Certification is increasingly requested by large customers in regulated industries.

GDPR and similar privacy laws

The EU General Data Protection Regulation applies to personal data of people in the EU, and many other jurisdictions have similar laws.

Principle or rightWhat it means here
Lawful basisThe company deploying the assistant needs a basis for processing employee or customer data, often legitimate interest with an assessment. Your customers decide this as controllers. You support them as a processor
Purpose limitationData used for answering questions is not reused for unrelated purposes, such as training models, without a basis
Data minimizationSend only needed content to models. Keep logs free of content by default
Storage limitationRetention schedule with deletion
Right of accessExport a user's conversations and data on request
Right to erasureDeletion that reaches every copy, including indexes and traces
International transfersModel calls to providers in other countries are transfers. Need appropriate safeguards, or processing in-region
ProcessorsModel providers and other vendors are processors or subprocessors, with DPAs
Data protection impact assessment (DPIA)Usually required for large-scale processing of employee data or new technologies. Your customers will ask for input
Automated decision-makingDecisions with legal or similarly significant effects based solely on automated processing are restricted. Human oversight design matters

EU AI Act

A risk-based regulation for AI systems placed on the market or used in the EU, with obligations phasing in over several years. Check the current timeline and guidance with counsel, as details continue to be clarified.

The broad structure:

CategoryExamplesObligations, broadly
Prohibited practicesSocial scoring, certain manipulative practices, emotion recognition in workplaces with narrow exceptionsNot allowed
High-risk systemsAI used in employment decisions (recruiting, promotion, termination, task allocation, monitoring), credit scoring, access to essential services, and others listed in the ActRisk management, data governance, technical documentation, logging, transparency to deployers, human oversight, accuracy and robustness, conformity assessment, registration
Transparency obligationsSystems interacting with people, generated contentInform people they are interacting with AI. Label certain generated content
General-purpose AI modelsFoundation models from providersObligations mainly on model providers
Minimal riskMost other usesNo specific obligations, voluntary codes

For the reference assistant:

  • General Q&A and drafting is generally not high-risk, but it has transparency obligations: users must know they are interacting with AI.
  • Any use case in the employment area, such as screening candidates or evaluating performance, may be high-risk. This is why the prohibited and restricted uses list keeps those out unless separately assessed.
  • If you deploy a third-party model, the provider carries the general-purpose model obligations. You carry obligations for how you use it.

Note that roles matter: a company building and selling the assistant is a provider of the AI system. A customer using it is a deployer. Each has different duties.

HIPAA

The US Health Insurance Portability and Accountability Act applies to protected health information (PHI) handled by covered entities and their business associates.

If customers in healthcare want to use the assistant with PHI:

  • You need a Business Associate Agreement (BAA) with the customer, and BAAs with every subprocessor that touches PHI, including model providers. Not every provider or model offers a BAA. Check per model and service.
  • Access controls, audit logs, encryption, and breach notification processes must meet HIPAA's security rule.
  • Restrict PHI-handling tenants to covered providers and regions through model gateway configuration.

Mapping table

ControlSOC 2ISO 27001ISO 42001GDPREU AI Act
SSO and RBACYesYesSecurity of processing
Permission-filtered retrievalYesYesConfidentiality
Encryption and key managementYesYesSecurity of processing
Retention and deletionYesYesStorage limitation, erasure
Audit logsYesYesYesAccountabilityLogging for high-risk
Eval datasets and CI gatesChange managementYesLifecycle controlsAccuracyAccuracy and robustness
Risk tiers and impact assessmentsRisk assessmentRisk assessmentYesDPIARisk management
Human confirmation for actionsHuman oversightAutomated decisionsHuman oversight
Transparency notices and system cardYesTransparencyTransparency, documentation
Vendor reviews of model providersYesYesThird partiesProcessor contracts

Checklist

  • Legal has confirmed which frameworks and laws apply.
  • SOC 2 Type II or ISO 27001 is planned or in place before selling to large enterprises.
  • Prompt and model changes are part of change management evidence.
  • Model providers are covered in vendor management, with DPAs and, where needed, BAAs.
  • Privacy rights (access, erasure) are supported across all stores.
  • Use cases are classified against AI regulation categories.
  • Transparency obligations are met in the UI.

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