Gapless

Governance Process

The lightweight process for approving use cases and changes, writing impact assessments, keeping documentation current, and reviewing incidents, without slowing teams down.

Governance answers: who decided this, based on what, and who is watching it now? Done well, it is a few templates, clear thresholds, and a small group that meets regularly. Done badly, it is a months-long approval queue that teams route around.

What needs approval

ChangeApprovalEvidence required
Bug fixes, UI changesNormal code reviewTests
Prompt changeCode review plus eval ownerEval report from CI
Model change (same task)AI leadEval report including safety and slices. Data terms of the new model checked
New model providerAI lead plus security and privacyVendor review, data processing agreement, eval report
New connector or data sourceProduct owner plus securityPermission mapping verified, scope defined
New tool with side effectsProduct owner plus securityThreat model for the tool, confirmation design, tests
New low-tier use caseProduct ownerEval set for the use case
New medium-tier use caseProduct owner plus domain ownerRisk assessment, eval set, human review design
New high-tier use caseResponsible AI review groupImpact assessment, bias testing, legal review, monitoring plan

Make the low-risk paths fast. Most changes should need nothing beyond code review and an automated eval report.

Impact assessment

Required for high-tier use cases. Keep the template short enough that people fill it in honestly.

# Impact assessment: Contract risk screening

## Use case
What it does, who uses it, what decisions it informs.

## People affected
Users, and anyone the output is about or sent to.

## Benefits
Measurable: time saved, errors caught.

## Risks
| Risk | Likelihood | Severity | Mitigation | Owner |
| Missed risky clause | Medium | High | Lawyer reviews every contract; tool is an aid | Legal ops |
| Over-reliance on summary | Medium | Medium | Clause-level citations; training | Legal ops |
| Confidential data exposure | Low | High | Matter-level permissions; no cross-matter retrieval | Security |

## Data
Sources, categories, retention, providers, legal basis.

## Evaluation
Datasets, results, slice results, red team summary, known weaknesses.

## Human oversight
Who decides, what they see, how decisions are recorded.

## Monitoring
Metrics, review cadence, triggers for re-assessment.

## Decision
Approved / approved with conditions / rejected. By whom. Date. Review date.

The review date matters. Assessments go stale as models, data, and usage change. Reassess yearly, and after any major change to the model or use case.

Documentation that stays current

Governance documentation fails when it lives in a separate system nobody updates. Keep it next to the code:

docs/governance/
  system-card.md
  use-cases/
    policy-qa.md                 (low tier)
    customer-reply-drafts.md     (medium tier, risk assessment)
    contract-screening.md        (high tier, impact assessment)
  models.md                      (model records)
  adr/                           (architecture decision records)

Require updates to these files in the same pull request as the change they describe. A pull request that adds a tool without updating the use case document fails review.

Incident review

An AI incident is any event where the assistant caused or nearly caused harm: a data leak, a harmful answer that was acted on, an unauthorized action, a biased output that reached someone.

  1. Respond: contain the issue using the security incident process. See Infrastructure security.
  2. Record: what happened, who was affected, the trace, and the timeline.
  3. Review within two weeks, blameless: root cause in the system, not "the model made a mistake". Why did the controls not catch it?
  4. Act: fixes with owners, new test cases in the safety or regression set, documentation updates.
  5. Report: to the review group, and to affected tenants and regulators where required.

Track near misses too, such as a guardrail that caught something serious, or a user who rejected a harmful action. They show where the controls are being tested.

Regular reviews

ReviewCadenceParticipants
Quality and safety metricsWeeklyAI team
Sampled answer reviewWeeklyDomain owners
Use case portfolio and incidentsMonthlyReview group
High-tier use case reassessmentYearly or on changeReview group, domain owner, legal
Red team exerciseTwice a yearAI, security, domain teams
Policy and prohibited usesYearlyReview group, legal

Regulation

Rules for AI vary by jurisdiction and change often. The EU AI Act, for example, sets obligations based on risk level, with stricter requirements for high-risk uses such as employment decisions. Sector rules (finance, health) and data protection law (GDPR and others) also apply.

The process on this page, with risk tiers, impact assessments, documentation, human oversight, and monitoring, is the foundation most of these rules expect. Work with legal counsel to map your specific obligations. See Compliance and legal.

Checklist

  • Approval requirements are defined per type of change, with fast paths for low risk.
  • High-tier use cases have impact assessments with review dates.
  • Governance documents live in the repository and update with the code.
  • Incidents and near misses get blameless reviews that produce test cases.
  • Regular reviews run on a fixed cadence.
  • Legal has mapped applicable regulations to the process.

On this page