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AIGP cheat sheet · Domain IV · BoK v2.1

Domain IV: Governing AI deployment and use

IV.A Deciding to deploy (6 to 8 exam questions)

Evaluate key factors and risks relevant to the decision to deploy the AI system.

IV.A.1 · Is AI even the right tool for this job?

  • Domain IV takes the deployer's view: the organization putting AI to work, bought or built.
  • Five context checks: business objectives, performance requirements, data availability, ethics and workforce readiness.
  • Set performance requirements for your own context; vendor benchmarks aren't your requirements.
  • Data availability includes the legal right to use the data, not just having it.
  • Workforce readiness means training, role design and calibrated trust for everyone affected, not just IT; organizational readiness adds budget, data and security maturity, and risk tolerance.
Deployer:
The organization that uses an AI system under its own authority, whether it bought the system or built it.
Use-case context:
The business objectives, performance requirements, data availability, ethical considerations and workforce readiness that decide whether an AI deployment makes sense.
Performance requirements:
The accuracy, speed, explainability, availability and error tolerance a specific use demands, set by the deployer for its own context.
Data availability:
Whether suitable, good-quality data exists and the organization has the right to use it for the intended purpose.
Workforce readiness:
Whether the people who will use, oversee or be affected by an AI system have the skills, training, roles and trust to work with it well.
Organizational readiness:
Whether the organization has the leadership, budget, data governance, security and privacy maturity, risk tolerance and operating capacity to support an AI deployment.

Exam tips: When a stem lists facts a confident sponsor is ignoring (unlabeled data, untrained staff, no success metric), those ignored facts usually point to the answer. · FIRST questions about a new deployment usually reward defining the use case and its context before pilots, vendors or models. · Benchmarks answer only the performance question, and only on the vendor's data. They never settle a deploy decision on their own. · 'Don't use AI here' can be the right answer. Take options seriously when they question whether AI fits at all.

IV.A.2 · Model menu: four ways to tell models apart

  • Four axes: classic vs. generative, proprietary vs. open, small vs. large, language vs. multimodal.
  • Generative models add confabulation, IP and harmful-content risks.
  • Open weights give control and transparency but put hosting, security and safety on you, under the license's terms.
  • Small models are easier to test, explain and host privately; large ones are broader but harder to evaluate.
  • Multimodal capability adds new attack channels and sensitive-data risks.
Classic (predictive) AI:
Models that classify, score or forecast from inputs rather than create new content.
Generative AI:
Models that create new content such as text, images, code or audio.
Proprietary (closed) model:
A model whose code and weights are not published; you use it under license or through an API.
Open-weights model:
A model whose trained parameters are published for download, usually under a license that may still carry conditions.
Multimodal model:
A model that processes more than one type of data, such as text together with images, audio or video.

Exam tips: Model-type questions often describe a model in one sentence and flip one axis in each wrong option. Check all four axes. · 'Open' never means 'no conditions'. Look for license limits on commercial use, attribution and acceptable use. · Bigger is rarely the governance answer. Labeled history plus fixed categories points to a classic model. · Closed models shift evidence-gathering to vendor diligence; they never shift accountability off the deployer.

IV.A.3 · Where should it run? Cloud, on-prem or edge

  • Cloud = scale and convenience, with data leaving your walls and shared responsibility.
  • On-premise = maximum control and inspectability, and all the security work is yours.
  • Edge = low latency, offline operation and local data, but hard fleet updates and monitoring.
  • Hybrid mixes environments (for example, edge inference with cloud training): more fit, more integration work.
  • Choose by data sensitivity, control needs and connectivity, not by hype or headline cost.
Cloud deployment:
Running an AI system on a provider's remote infrastructure, typically as a managed service.
On-premise deployment:
Running an AI system on servers the organization owns and operates itself.
Edge deployment:
Running an AI model directly on an end device such as a phone, camera, vehicle or sensor.
Shared responsibility model:
The split of security and compliance duties between a cloud provider (infrastructure) and its customer (data, access and use).
Data residency:
A requirement that data be stored or processed within a particular country or region.
Hybrid deployment:
Combining environments, such as edge or on-premise inference with cloud training and updates, so each workload runs where it fits.

Exam tips: When several options satisfy the loud constraint (such as residency), the answer turns on the quiet one: offline operation, physical control or auditability. · Residency is not control. An in-country cloud region keeps data local, but the provider still operates the hardware. · Moving to the cloud moves the work, never the accountability. · Edge is the answer when latency, offline operation or on-device privacy is a hard requirement. Expect follow-ups about updating and rolling back a fleet, and about slimming models (quantization, distillation) at some cost in accuracy.

IV.A.4 · Make it fit: prompts, RAG, fine-tuning, agents

  • As is → prompting → RAG → fine-tuning → agents: each adds fit and power, and shifts responsibility to you.
  • RAG keeps knowledge fresh and citable, but the document store needs access control, quality checks and injection defenses.
  • Fine-tuning changes the model: govern the training data, re-test safety, and check whether you've become a provider.
  • Agents need least privilege, human approval for high-impact actions, action logs and a way to stop and roll back.
Prompt engineering:
Shaping a model's behavior through the instructions and examples sent with each request, without changing the model.
Retrieval-augmented generation (RAG):
A technique where the system retrieves relevant documents at query time and adds them to the prompt, leaving the model's weights unchanged.
Fine-tuning:
Further training a pre-trained model on your own examples, which permanently changes its weights.
Agentic architecture:
A design in which a model plans steps and calls tools to take actions toward a goal with limited human input.
Excessive agency:
OWASP's term for an AI system with more functionality, permissions or autonomy than its task needs.
Indirect prompt injection:
Malicious instructions hidden in content the model reads, such as a retrieved document or web page, that hijack its behavior.

Exam tips: Changing content + citations + no training budget = RAG. Stable format + huge volume + cost pressure = fine-tuning. · Upgrading from answers to actions raises permissions, logging, human approval and rollback. Training-data risks are unchanged by that upgrade. · Fine-tuning or repurposing can make a deployer the provider under EU AI Act Art. 25. Watch for 'substantial modification' and 'changes the intended purpose'. · A system prompt is guidance, not a security control.

IV.B Assess before you deploy (5 to 7 exam questions)

Perform key activities to assess the AI system.

IV.B.1 · Impact assessment: your system, your context

  • Deployers must perform or review an impact assessment of the selected system in their own context.
  • Review vendor evidence critically, then add what only you know: workflow, affected people, oversight, redress.
  • The FRIA is a deployer duty for public bodies, public-service providers, credit scoring and life/health insurance pricing.
  • Test on representative local data and break results down by group.
  • Assess before first use, decide, document, and keep it updated.
Deployer impact assessment:
An assessment of how a selected AI system will affect people and the organization in the deployer's own context, done before use and kept up to date.
Fundamental rights impact assessment (FRIA):
An EU AI Act assessment (Art. 27) that certain deployers of high-risk AI must complete before first use, covering affected groups, risks, oversight and remedies.
Data protection impact assessment (DPIA):
A GDPR assessment that a controller must carry out before processing personal data in ways likely to pose a high risk to people's rights.
ISO/IEC 42005:
An international standard (2025) giving guidance on assessing the impacts of AI systems on individuals, groups and society.
Disaggregated evaluation:
Breaking performance and error rates down by relevant groups to reveal problems that overall averages hide.

Exam tips: Know each assessment's owner: FRIA = deployer (public bodies, private entities providing public services, credit scoring, life and health insurance pricing); conformity assessment = provider; DPIA = controller. · 'The vendor already assessed it' is the classic trap. Vendor documents are inputs, never substitutes. · Timing: before first use, then updated when things change. 'After a pilot on real people' is too late. · Prefer evidence from your own population, broken down by group, over headline benchmark numbers.

IV.B.2 · Read the fine print: AI vendor contracts

  • Check data clauses first: training on your data, output ownership, retention, location and subprocessors.
  • Read indemnities alongside their exclusions, and liability caps alongside their carve-outs.
  • Operational terms matter later: model change notice, SLAs, audit and testing rights, documentation, exit.
  • Contracts allocate money and duties between parties, never accountability to the people affected.
IP indemnity:
A vendor's promise to defend and compensate the customer if the AI system or its outputs infringe third-party intellectual property.
Liability cap:
A contractual ceiling on the damages one party can recover from the other, often with carve-outs for specific harms.
Model change notification:
A contract term requiring the vendor to give advance notice of material changes to the model, often paired with version pinning.
Audit rights:
The customer's contractual right to obtain evidence of, or directly check, the vendor's controls and compliance.
Subprocessor:
A third party the vendor engages to process the customer's data, such as a hosting provider.
Exit assistance:
Contract terms covering data return, certified deletion and transition support when the relationship ends.

Exam tips: Contract questions are mapping exercises: restate the risk in one sentence, then pick the clause whose mechanism touches it. · Indemnities and higher caps pay out after harm. Notice, testing and audit rights prevent or detect it. If the stem says 'prevent' or 'detect', choose the latter. · No clause transfers the deployer's accountability to affected people or regulators. · Clauses that forbid testing, benchmarking or auditing are red flags: they block the deployer's own assessment duties.

IV.B.3 · Building your own model: control vs. liability

  • Building your own model gives control, data privacy, customization and differentiation.
  • It also means increased obligations and higher potential liability, with no vendor to share them.
  • Under the EU AI Act, building for your own use can make you both provider and deployer.
  • Training-data rights, documentation, security and monitoring all become permanently yours.
Proprietary model (own):
An AI model an organization develops or trains itself and controls, rather than licensing from a vendor.
Provider (EU AI Act):
Whoever develops an AI system, or has it developed, and places it on the market or puts it into service under its own name, including for its own use.
Putting into service:
Supplying an AI system for first use to a deployer, or for the provider's own use, in the EU for its intended purpose.
Product liability:
Liability for harm caused by defective products, which under the revised EU Product Liability Directive extends to software, including AI.
Build vs. buy:
The choice between developing your own AI model and licensing one, which shifts control, obligations and liability.

Exam tips: Build vs. buy in one line: your own model = more control, more obligations, more liability. Any option saying ownership lightens the legal load is the planted error. · 'Putting into service' includes your own use, so an internal-only model can still make you a provider. · The BoK says Domain IV applies whether you deploy your own model or a third party's. Being the provider adds duties; it never removes deployer duties.

IV.B.4 · Open licenses and vendor due diligence

  • BoK v2.1 says 'vendor or licensing agreement': open models, code and datasets all come with binding terms.
  • Permissive = keep notices; copyleft = share alike on distribution (AGPL: network use too); responsible-AI = obey and pass on use limits; non-commercial = keep out of products.
  • Watch output rights, dataset privacy terms, tiered access, changing terms, inherited duties and compatibility.
  • Do due diligence before negotiating, ask for ISO/IEC 27001, ISO/IEC 42001 and SOC 2 Type II evidence, and turn every gap into a term, a control or a walk-away.
Permissive license:
An open license, such as MIT or Apache 2.0, that allows commercial use and modification as long as notices are kept.
Copyleft license:
An open license, such as the GPL, that requires derivative works to be released under the same terms when they are distributed.
AGPL network clause:
The GNU Affero GPL term that treats offering modified code as a network service like distributing it, triggering source-sharing duties.
Responsible AI license (RAIL):
A license that permits use of a model or code but bans listed harmful uses and requires those restrictions to be passed downstream.
Vendor due diligence:
Investigating a vendor's documentation, assurance evidence and track record before negotiating, so the findings shape the contract.
SOC 2 Type II report:
An independent auditor's report on whether a service provider's controls operated effectively over a period, typically 6 to 12 months.

Exam tips: 'Open' never means 'no conditions'. Ask three questions: may we use it commercially, what must we pass on, and which uses are banned? · Copyleft bites on distribution; the AGPL also bites when modified code runs as a network service. Permissive licenses mostly ask you to keep the notices. · Due diligence comes before negotiation: the findings decide which clauses you need. · SOC 2 Type II tests controls over a period; Type I only checks their design at a point in time. ISO/IEC 42001 certifies an AI management system, not a model.

IV.B.5 · Own model: protect it, explain it, govern it

  • Owning a model brings opportunities: a protectable asset, full explainability and governance on your terms.
  • IP strategy: catalog assets, secure ownership with IP assignment and license audits, then choose trade secret, patent or copyright.
  • Defend against extraction with API-only access, rate limits, query monitoring, minimal outputs and watermarks.
  • Explain with interpretable models, local and global methods (LIME, SHAP) and counterfactuals, in plain language.
  • Govern with a review board, a named model owner, development-cycle gates, change control and independent validation.
Trade secret:
Confidential business information, such as model weights or curated data, protected for as long as reasonable steps keep it secret.
IP assignment:
A contract clause transferring ownership of work created by employees or contractors to the company.
Model extraction:
Copying a model's behavior by querying it many times and training a look-alike model on the responses.
Local vs. global explanation:
A local explanation shows why one output occurred; a global explanation shows what drives the model's behavior overall.
Counterfactual explanation:
An explanation that tells a person what would have needed to be different for the outcome to change.
Model owner:
The named person accountable for a model's performance, documentation and risks throughout its life.

Exam tips: v2.1 asks for risks AND opportunities of your own model: control, explainability and a protectable asset are the opportunities. · Theft defenses are layered: API not weights, least-privilege access, rate limits, query monitoring, watermarks, terms of use. 'Too complex to copy' is never the answer. · Local = why this decision; global = what drives the model overall. Affected people need local, plain-language reasons, and counterfactuals are a strong choice. · Building it yourself doesn't skip governance: review board, named owner, development-cycle gates, change control and independent validation.

IV.C Run it responsibly (9 to 11 exam questions)

Govern the deployment and use of the AI system.

IV.C.1 · Policies go live: running AI by the rulebook

  • Deployment is where policies must operate: data governance, risk management, issue management and user training.
  • Production data governance = input rules, minimization, retention limits, input quality, access control, and the transfer and notice duties that go-live triggers.
  • Keep the risk register alive with scheduled and change-triggered reviews.
  • Issue management needs easy reporting, triage, escalation and closure.
  • Role-based, ongoing training is the main defense against automation bias.
Automation bias:
The tendency to over-trust an automated system's output instead of exercising independent judgment.
Risk register:
A living record of identified risks, each with an owner, rating, treatment and review date.
Issue management:
The process for capturing, triaging, escalating and resolving problems with a live system, and learning from them.
Data minimization:
Collecting and keeping only the data a defined purpose actually needs.
Role-based training:
Training tailored to what each group (end users, overseers, leaders) needs to do with an AI system.

Exam tips: When the stem says the model meets spec but outcomes are bad, the lever is human: training, usage policy, verification duties. · 'Keep everything in case it's useful' is never a purpose. Minimization and retention limits win. · Training is a standing control with refreshers. One-off launch briefings are the distractor. · Banners and disclaimers alone don't change behavior. Prefer options that assign duties and build skills.

IV.C.2 · Keep watching: monitoring and maintenance

  • Deployers monitor in their own context: performance, drift, fairness, output quality, oversight signals, usage and vendor changes.
  • Every metric needs a threshold, an owner and a planned response.
  • Maintenance runs on a calendar plus triggers, under change management.
  • Vendor upgrades need re-validation; version pinning buys the time.
  • Separate development, staging and production, keep builders out of production, and track every version in a model registry.
Continuous monitoring:
Ongoing, largely automated tracking of a live AI system's performance, inputs, outputs and use against defined thresholds.
Data drift:
A shift in the distribution of a system's live inputs away from the data it was trained or validated on.
Concept drift:
A change in the real-world relationship between inputs and outcomes, so learned patterns stop holding.
Version pinning:
Staying on a specific, validated model version until a newer one has been tested and approved.
Change management:
Testing, approving, documenting and preparing rollback for every change to a production system.
Model registry:
A catalog of model versions recording each one's hash, training-data identifiers, evaluation results, owner and deployment status.

Exam tips: Proactive beats reactive: continuous monitoring plus a scheduled maintenance plan. 'Freeze it' and 'retrain only when it breaks' are the two planted extremes. · A vendor update is a change to YOUR system. Re-validate before it reaches production. · Deployers of vendor models usually maintain through configuration, data, oversight and vendor escalation, not retraining. · Monitoring isn't only model metrics: override rates, usage patterns and complaints catch human and scope problems.

IV.C.3 · Stress-test it: audits, red teams, threat models

  • Four periodic tools: audits, red teaming, threat modeling and security testing. Each finds different problems.
  • Deployers assess the system as they run it, not just the model.
  • Negotiate testing and audit rights with vendors; some laws put audit duties on deployers directly.
  • Set cadence by risk, add change triggers, keep assessors independent, and track findings to closure.
Audit:
An independent check of a system and its governance against defined criteria such as policy, law, contract or standards.
Red teaming:
Simulating real adversaries who actively try to make an AI system fail, misbehave or leak data.
Threat modeling:
Structured, on-paper analysis of how a system could be attacked or misused, ranked by likelihood and impact.
Security testing:
Technical testing of security controls, such as penetration tests, vulnerability scans and access checks.
MITRE ATLAS:
A public knowledge base of real-world adversary tactics and techniques used against AI systems.
Threat hunting:
Proactively searching a live system's logs and telemetry for signs of compromise or abuse that automated alerts have missed.

Exam tips: Read the verb: checks against criteria = audit; attacks = red teaming; analyzes on paper = threat modeling; tests controls = security testing; searches live logs for intruders = threat hunting. · 'No attacks were executed' is the tell for threat modeling. · Cadence answers reward 'risk-based plus change-triggered'. A fixed calendar alone is the near miss. · Deployers need contractual permission and a scope covering the whole system: prompts, RAG, plug-ins and people.

IV.C.4 · Write it down: incidents, risks and PMM plans

  • Know the difference: risk (could happen), issue (has happened, no significant harm), incident (harm).
  • Good incident records cover detection, impact, containment, root cause, notifications, fixes and lessons.
  • EU high-risk deployers keep logs for at least six months and must inform the provider of risks and serious incidents.
  • Providers own post-market monitoring; deployers feed it and should keep their own monitoring plan.
Serious incident (EU AI Act):
An incident or malfunction leading to death or serious harm to health, serious and irreversible disruption of critical infrastructure, breach of fundamental-rights obligations, or serious harm to property or the environment.
Post-market monitoring:
A provider's system for actively collecting and analyzing data on an AI system's performance throughout its life, fed in part by deployers.
Near miss:
An event that could have caused harm but was caught in time; worth recording as an issue.
Incident record:
A documented account of what happened, its impact, containment, root cause, notifications, corrective actions and lessons.
Post-deployment monitoring plan:
A deployer's documented plan covering metrics and thresholds, user feedback, appeals and overrides, incident response, change management and decommissioning (NIST AI RMF MANAGE 4.1).

Exam tips: Incident order: detect → contain → notify → investigate → correct → learn. Reporting before containing, or reviewing before notifying, are the classic inversions. · Post-market monitoring belongs to the provider (Art. 72), but deployers must monitor and inform the provider (Art. 26(5)). 'Leave it all to the vendor' is wrong. · Record near misses and minor issues: patterns turn into risks. · Guides order incident steps differently, and some put 'communicate' first. Early communication means internal escalation; when harm is ongoing, containment still comes before external notices.

IV.C.5 · Beyond the intended use: misuse and ripples

  • Uses drift through scope creep, deliberate misuse and data repurposing.
  • Forecast with intended and out-of-scope use statements, pre-mortems, misuse brainstorming and stakeholder mapping.
  • Reduce with technical, contractual, organizational and documentation controls.
  • Treat every new use as a new deployment that needs assessment.
Secondary use:
Use of an AI system, or its data, for a purpose beyond the one that was assessed and approved.
Function creep:
The gradual expansion of a system into tasks it was never designed or assessed for.
Downstream harm:
Harm that ripples beyond the original decision or user, including to people who never used the system.
Out-of-scope use:
A use the deployer or provider has identified as inappropriate or unsupported, documented so it can be prevented.
Purpose limitation:
The GDPR principle that personal data collected for one purpose may not be further processed in ways incompatible with it.
Pre-mortem:
A forecasting exercise that imagines a future failure and works backward to what caused it.

Exam tips: Model card = what this system is for and not for. AI inventory = which systems we have. Secondary-use questions point to the model card and impact assessment. · A new use of an approved system is a new deployment. Assess it before it goes live, even if the technology is unchanged. · Repurposing into a high-risk area (hiring, credit, worker monitoring) can make a deployer the provider under Art. 25(1)(c). · Downstream harms include people who never used the system.

IV.C.6 · Telling the world: external communication

  • Plan audiences, messages, timing, channels, incident communications and approvals in advance.
  • Tell people AI is in use, what it can and can't do, and how to reach a human or contest an outcome.
  • EU deployers have specific duties: informing decision subjects, explaining decisions, labeling deepfakes.
  • In incidents: required notifications and affected people first, one voice, honesty over spin.
  • Offer a real human or non-AI alternative for significant decisions; GDPR Art. 22, California's ADMT rules and Colorado SB 26-189 require versions of it.
External communication plan:
A pre-agreed plan for what an organization tells users, affected people, regulators, partners and the public about its AI, when and through which channels.
AI disclosure:
Telling people, at or before first interaction, that they are dealing with an AI system or AI-generated content.
Right to explanation (EU AI Act Art. 86):
The right of a person affected by a significant decision based on an Annex III high-risk system to a clear, meaningful explanation from the deployer of the AI's role and the main elements of the decision.
AI washing:
Exaggerating or misrepresenting what an AI system can do, which can amount to deceptive marketing.
Holding statement:
A pre-drafted initial public statement used in the first hours of an incident while facts are confirmed.
Non-AI alternative:
A human or non-automated route offered instead of an AI process; it should be feasible, clearly explained, easy to choose and no worse in service.

Exam tips: The winning answer is the balanced pair: capabilities AND limitations. Hype, hiding and silence are the three standard distractors. · Timing matters: disclose at or before first interaction. A notice after the fact is a deficiency even if the wording is fine. · Technical internals are rarely what affected people need. Look for plain-language, actionable information and a route to a human. · Overstated AI claims are a legal risk (deceptive practices), not just a brand risk.

IV.C.7 · The off switch: deactivate or localize

  • Every deployed AI needs a policy and controls to deactivate or localize it.
  • Risk-driven triggers are regulatory or performance/safety, never profit or a new release; planned retirement can follow business or vendor reasons.
  • Toolkit: kill switch, feature flags, geo-restriction, rollback, graceful degradation, agent stop controls; localize with flags, regional modules, country models or federated learning.
  • The policy settles triggers, decision rights, fallback, notifications, evidence, restoration and drills.
Kill switch:
A control that stops an AI system globally and quickly, ideally leaving it in a safe state.
Feature flag:
A switch that turns a feature on or off for a jurisdiction, customer group or cohort without redeploying software.
Localization:
Restricting or adapting how an AI system operates by region, for example disabling it in one jurisdiction or running a country-specific model.
Rollback:
Returning a system to its last known-good model version or configuration.
Graceful degradation:
Falling back to human handling or a simpler process so service continues when the AI is switched off.
Deactivation policy:
A pre-agreed policy setting the triggers, decision rights, controls, fallbacks, notifications and restoration criteria for switching an AI system off or restricting it.

Exam tips: For risk-driven deactivation, valid triggers are regulatory or performance/safety problems; profit, migration hassle and 'a new version exists' are never the answer. Planned retirement (IV.C.8) can legitimately follow business or vendor reasons. · A timely, verified mitigation is a legitimate reason to keep a system running. · One jurisdiction's demand → feature flag or geo-restriction. A severe global incident → kill switch. The kill switch for a local issue is the overbroad trap. · Look for pre-agreed decision rights and tested controls. An untested switch isn't a control.

IV.C.8 · Retire it well

  • Planned retirement and risk-driven deactivation are different processes with different valid triggers.
  • A retirement policy sets criteria, decision rights, required steps, evidence and a lessons-learned review.
  • Sequence: map dependencies, notify, transition (including a non-AI fallback), snapshot and shut down, retain or dispose, close out.
  • Archive what accountability and the law require; destroy the rest, including stray model copies, and get certificates from hosts.
  • Mark the system retired in the inventory and registry, exit the contract, and keep the retention clock running.
Planned retirement:
Ending an AI system's use on a schedule for reasons such as obsolescence, vendor end of support, a replacement or a changed business need.
Risk-driven deactivation:
Switching off or restricting a live AI system because of a regulatory, performance, safety or security problem, under the deactivation policy.
Decommissioning:
The controlled process of retiring a system: mapping dependencies, notifying users, transitioning, archiving or destroying data and models, and closing the records.
Retention schedule:
A documented set of rules saying how long each type of record is kept and when it must be destroyed.
Certificate of destruction:
Written confirmation from a provider or contractor that specified data or model copies have been permanently destroyed.
Non-AI fallback:
A manual or rules-based process that takes over an AI system's work when it is switched off or retired.

Exam tips: Read the trigger first. Business or vendor reasons point to planned retirement, which is legitimate; an emergency stop needs a regulatory or performance problem. · Sequence: map, notify, transition, snapshot and shut down, retain or dispose, close out. 'Delete everything first' and 'update the inventory first' are the planted inversions. · Retirement doesn't end retention duties: EU provider documentation runs 10 years from placing on the market, logs at least six months, Colorado records three years. · Deleting the production model isn't disposal. Look for fine-tuned copies, checkpoints, backups and vendor-hosted copies.

Independent study aid, not affiliated with the IAPP. Written with AI from primary sources; laws change, so check the sources. Last updated 7 Nov 2026.