Guardian Review Checklist¶
The Guardian safeguards the ethical and legal frameworks of an AI system. This checklist guides the Guardian through all formal review moments in the lifecycle — from Gate 1 through decommissioning.
Two-Man Rule for High Risk
For AI systems with risk classification High, explicit approval is required from two people: the Privacy & Legal Officer (tests against GDPR + EU AI Act) and the AI Quality Ethicist / QA Lead (tests for bias, Golden Set quality, output safety).
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1. Mandate & Independence¶
Ensure the mandate is clearly documented before the first review.
- Guardian has been formally appointed and accepted by the project team.
- Mandate includes veto rights at all Gate Reviews.
- Guardian has no direct interest in the project outcome (independence).
- For High Risk: Two-Man Rule active (Privacy Officer + AI Quality Ethicist both appointed).
- Contact persons and escalation paths are documented.
2. Gate 1 Review — Discovery & Strategy¶
Moment: Before go-ahead to Validation (PoV).
Risk & Scope¶
- Risk Pre-Scan has been completed and risk classification determined.
- Risk classification is realistic (not underestimated to avoid compliance).
- For High Risk: EU AI Act Article 9 (risk management system) applies — confirmed.
Hard Boundaries & Objective Card¶
- Objective Card has been drawn up with explicit Hard Boundaries (what is the system absolutely not allowed to do?).
- Hard Boundaries are concrete and verifiable (no vague formulations).
- Green AI considerations have been completed (Section E of the Objective Card).
- Guardian has approved and signed the Hard Boundaries.
Gate 1 outcome:
- Approved — proceed to Validation (PoV)
- Approved with conditions: _________________
- Rejected — reason: _________________
Guardian signature: __________ Date: __________
3. Gate 2 Review — PoV Investment¶
Moment: Before go-ahead to Development.
Dataset & Fairness¶
- Training dataset is documented (source, size, date range).
- Dataset has been checked for representational bias (age, gender, geography, etc.).
- Privacy-sensitive data has been identified and anonymised or masked.
- Data sourcing complies with GDPR (lawful basis, data minimisation).
Business Case & Proportionality¶
- Business Case is ethically justified: benefits outweigh risks.
- Is AI proportionate? Can a simpler system (rule-based, smaller model) perform the same task?
- Planned AI contribution is realistic (no AI Productivity Paradox pitfall; expected organisation-wide gain 5–15%).
Hard Boundaries in Objective Card¶
- Hard Boundaries are recorded in the Objective Card (Section D).
- Hard Boundaries cannot be changed without Guardian approval.
Gate 2 outcome:
- Approved — proceed to Development
- Approved with conditions: _________________
- Rejected — reason: _________________
Guardian signature: __________ Date: __________
4. Gate 3 Review — Go-Live (Production)¶
Moment: Before going live in production.
Red Team & Safety¶
- Red Team session has been conducted (mandatory for High Risk).
- No open Critical or High findings in the Red Team report.
- OWASP Top 10 LLM 2025 has been completed as minimum scope.
- Deceptive Delight and HashJack attack patterns have been tested.
- AI Safety Checklist has been completed and approved.
Compliance¶
- GDPR: privacy impact has been assessed; DPIA conducted where required.
- EU AI Act: technical dossier is up to date (for High Risk systems).
- Traceability report is present (from data to output).
- Prompts are versioned and documented (per Prompt Versioning template).
Operational Readiness¶
- Incident response plan is active and tested.
- Monitoring and alerting are configured (drift, hallucination rate, MTTD \< 15 min).
- Decommissioning triggers are documented in the monitoring configuration.
- Handover to management organisation is complete (Handover Checklist signed off).
Gate 3 outcome:
- Approved for go-live
- Approved with conditions: _________________
- Not approved — open findings: _________________
Guardian signature (Privacy Officer): __________ Date: __________
Guardian signature (AI Quality Ethicist): __________ Date: __________
5. Ongoing Oversight (Post-Live)¶
Periodic Guardian checks after go-live.
Quarterly check¶
- Benefits Realisation Report received and reviewed.
- No unresolved incidents with Guardian escalation.
- Drift reports reviewed: no structural bias escalation.
- Kaizen Log updated with Guardian notes.
Annual re-review (mandatory for High Risk)¶
- Renewed Red Team session conducted.
- Legal framework re-assessed (EU AI Act updates, new regulations).
- Objective Card and Hard Boundaries reviewed for continued relevance.
6. Decommissioning Review¶
Moment: Upon shutdown of the AI system.
- Shutdown decision has been formally made by CAIO or steering committee.
- Users have been informed in good time (minimum 30 days in advance).
- Personal data has been deleted in accordance with GDPR (right to erasure).
- Models and configurations have been archived or destroyed (per policy).
- Knowledge transfer to management organisation is complete.
- Guardian final judgement documented in Kaizen Log.
Guardian signature: __________ Date: __________
Related modules:
- Roles & Responsibilities
- Red Teaming Playbook
- Objective Card template
- AI Safety Checklist
- Incident Response