Understanding the Phase 2 Audit
The Phase 2 audit is the critical on-site (or virtual) assessment where auditors verify the operational effectiveness of your Artificial Intelligence Management System (AIMS). Unlike Phase 1, which reviews documentation, Phase 2 delves into the practical application of your AI governance framework. The objective is to see tangible evidence that your policies are not just written down, but are actively followed, understood by staff, and demonstrably effective in managing AI risks.
Key Focus Areas:
- Clauses 8-10: Operation, Performance Evaluation, and Improvement.
- Annex A Controls: AI-specific controls like bias mitigation, data governance, and human oversight.
- Practical Implementation: Moving from "policy existence" to "policy efficacy".
- Staff Interviews: Gauging awareness, competence, and adherence.
Auditor's Goal:
An auditor's primary goal is to collect comprehensive evidence to ensure your AIMS is fully compliant and operationally effective. They will observe processes, interview staff, and evaluate the real-world performance of your AIMS to confirm it manages AI-specific risks responsibly.
Interactive Audit Questionnaire
Use the filters to narrow down questions by clause or topic. Click on any question to expand and see the detailed answer framework, evidence required, and common pitfalls to avoid. Use the ✨ buttons for AI assistance!
Essential Document Checklist
Track your documentation readiness for the audit. This list covers the key e-documents auditors will expect to review. Use the ✨ button to generate a document outline!
Reviewing AI-Generated Code for Responsible AI (RAI) Compliance
When reviewing a pull request (PR) with AI-generated code, your goal is to ensure the code adheres to RAI principles, which ultimately contribute to a trustworthy and ethical AI system. Use the search bar to find specific checks.
Your Role as the Reviewer: Key Principles
- Assume Nothing: Do not assume the AI got it right or fully understood the implications. Treat it with a healthy dose of skepticism, especially for critical path code.
- Context is King: Always relate the code back to the problem it's solving and the system it's integrating into.
- Tooling: Leverage static analysis tools, linters, and security scanners. While not perfect for RAI, they can catch basic errors that an AI might generate.
- Documentation and Comments: Demand clear comments and documentation for complex AI-generated logic. If you can't understand it, it's not RAI compliant from a transparency perspective.
- Ask "Why?": If a piece of code seems unusual or non-standard, ask "Why did the AI choose this approach?" (even if you're asking yourself) and try to deduce if there's a good reason or a potential risk.
- Regression Testing: Emphasize the importance of robust regression testing, especially when AI generates changes, to ensure no existing functionality is broken or degraded.
By systematically going through these checks, you can significantly enhance the RAI compliance of AI-generated code, ensuring it's not just functional, but also ethical, secure, and maintainable.
Best Practices for a Successful Audit
Follow these best practices to ensure your team and environment are fully prepared for the Phase 2 audit, facilitating a smooth and successful engagement.
Prepare Your Team
Conduct internal mock audits and simulate interview questions. Ensure all key personnel understand their roles within the AIMS and can articulate their responsibilities clearly.
Organize Your Evidence
Meticulously organize, index, and provide easy digital access to all required e-documents. A smooth retrieval process demonstrates maturity and control.
Communicate Effectively
Appoint a single point of contact for the auditors. Answer questions honestly and directly. If an answer is not immediately known, offering to find out and following up promptly is a professional and effective approach.
Handle Findings Proactively
Document any non-conformities identified. Develop prompt action plans with root cause analysis, corrective measures, responsibilities, and timelines.
Demonstrate Live Operation
Auditors expect to see at least three months of AIMS live operation. This includes evidence of completed internal audits and a management review before their arrival.
Embrace Continual Improvement
View the audit as an opportunity to improve. Use findings to drive enhancements to your AIMS, policies, and training programs, showcasing a dynamic and mature system.