Documentation makes or breaks ISO 42001 certification. Auditors don't just want to see that you have controls, they want evidence that those controls operate consistently. Here's what you actually need.
01
Mandatory Documentation
ISO 42001 requires documented information for both the management system and AI-specific controls.
Management System Documents
Required policies:
- AI Management System Policy (Clause 5.2)
- AI Risk Management Policy
- Information Security Policy (if not separate ISO 27001)
Required procedures:
- Document control procedure
- Risk assessment and treatment procedure
- Internal audit procedure
- Management review procedure
- Nonconformity and corrective action procedure
- Competence assessment procedure
Required records:
- Scope definition
- Risk register
- Statement of Applicability
- Training records
- Internal audit reports
- Management review minutes
- Corrective action records
AI-Specific Documentation
Annex A requirements:
- AI system inventory
- Impact assessment records
- AI lifecycle documentation
- Data provenance records
- Third-party assessment records
- Transparency information
- Human oversight records
02
AI System Documentation
Model Cards
Model cards provide standardized documentation for ML models. Key sections:
Model Details:
Model Name: Customer Churn Predictor v2.1
Model Type: Gradient Boosted Trees
Training Date: 2024-09-15
Version: 2.1.0
Owner: Data Science Team
Intended Use:
Primary Use: Predict customer churn probability
Users: Customer Success Team
Out of Scope: Credit decisions, pricing discrimination
Training Data:
Dataset: Customer interaction history 2021-2024
Size: 2.3M records
Features: 45 behavioral and demographic
Preprocessing: Anonymization, outlier removal
Known Limitations: Limited expatriate representation
Performance Metrics:
Accuracy: 87.3%
Precision: 84.1%
Recall: 79.8%
F1 Score: 81.9%
AUC-ROC: 0.912
Fairness Assessment:
Demographic Parity: Tested across nationality, gender, age
Equalized Odds: Within acceptable thresholds
Known Biases: Slight underperformance on <25 age group
Mitigation: Additional monitoring for young customer segments
Data Sheets
Data sheets document datasets used in AI systems.
Motivation:
- Purpose of dataset creation
- Creator and funder
- Intended uses
Composition:
- Instance count and types
- Feature descriptions
- Missing data handling
- Confidentiality considerations
Collection Process:
- Data sources
- Collection mechanisms
- Timeframe
- Consent and ethical review
Preprocessing:
- Cleaning steps
- Transformations applied
- Selection criteria
Distribution:
- Access controls
- Usage restrictions
- Licensing
03
AI Inventory and Asset Register
| Field | Description | Example |
|---|---|---|
| System ID | Unique identifier | AI-CRM-001 |
| Name | Descriptive name | Lead Scoring Model |
| Business Owner | Accountable executive | VP Sales |
| Technical Owner | Responsible engineer | ML Team Lead |
| Purpose | Business objective | Prioritize sales outreach |
| Risk Level | High/Medium/Low | Medium |
| Data Categories | Types of data used | Behavioral, demographic |
| Status | Active/Development/Retired | Active |
| Last Review | Most recent assessment | 2024-10-15 |
Field
System ID
Description
Unique identifier
Example
AI-CRM-001
Field
Name
Description
Descriptive name
Example
Lead Scoring Model
Field
Business Owner
Description
Accountable executive
Example
VP Sales
Field
Technical Owner
Description
Responsible engineer
Example
ML Team Lead
Field
Purpose
Description
Business objective
Example
Prioritize sales outreach
Field
Risk Level
Description
High/Medium/Low
Example
Medium
Field
Data Categories
Description
Types of data used
Example
Behavioral, demographic
Field
Status
Description
Active/Development/Retired
Example
Active
Field
Last Review
Description
Most recent assessment
Example
2024-10-15
04
Version Control
Major.Minor.Patch numbering (e.g., 2.1.3)
Change log with dates, authors, descriptions
Approval records for significant changes
Semantic versioning for models
Training data versioning
Configuration management
Rollback capability
Git for code and configuration
Document management system for policies
ML experiment tracking (MLflow, Weights & Biases)
05
Audit Trails
User authentication logs
Authorization changes
Administrative actions
Model deployment records
Prediction logs (sampling for volume)
Retraining events
Performance monitoring data
Review and approval records
Committee meeting minutes
Decision documentation
06
Document Retention
| Document Type | Minimum Retention | Notes |
|---|---|---|
| Policies | Life of system + 3 years | Retain superseded versions |
| Procedures | Life of system + 3 years | Track all versions |
| Training records | Employment + 3 years | Per employee |
| Audit reports | 5 years | Include corrective actions |
| Model cards | Life of model + 3 years | Version history |
| Risk assessments | 5 years | Include treatment evidence |
Document Type
Policies
Minimum Retention
Life of system + 3 years
Notes
Retain superseded versions
Document Type
Procedures
Minimum Retention
Life of system + 3 years
Notes
Track all versions
Document Type
Training records
Minimum Retention
Employment + 3 years
Notes
Per employee
Document Type
Audit reports
Minimum Retention
5 years
Notes
Include corrective actions
Document Type
Model cards
Minimum Retention
Life of model + 3 years
Notes
Version history
Document Type
Risk assessments
Minimum Retention
5 years
Notes
Include treatment evidence
07
Digital Tools
ServiceNow GRC
OneTrust
LogicGate
ML experiment tracking (MLflow, Neptune)
Model monitoring (Evidently AI, Fiddler)
Data lineage (Apache Atlas, Collibra)
SharePoint/Confluence for policies
Git-based for technical docs
Dedicated audit evidence repository
08
Common Audit Findings
Missing version history
Can't prove which version was active when
Unsigned approvals
Policies without executive signatures
Outdated documents
Procedures that don't match practice
Incomplete records
Training without attendee confirmation
Inaccessible evidence
Documents scattered across systems
09
References
- ISO/IEC 42001 Documentation Requirements
- Model Cards for Model Reporting (Google)
- Datasheets for Datasets (Microsoft)
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