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Risk Register

Ready

Purpose. The live record of data and AI risks: what could go wrong, how likely and how bad, what you are doing about it, and who owns it.

When to use it. Continuously. Review at every committee meeting; refresh scoring at least quarterly.

How to use it. Write risks as cause, event, and consequence — "because X, Y may happen, leading to Z". A register full of one-word risks like "data quality" cannot be managed, because nobody can tell what treating it would involve.

Closes assessment gaps

This template addresses Q11, Q29, Q34 in the readiness assessment.


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The template

Scoring

Likelihood

Score Level Guide
1 Rare Not expected in 5 years
2 Unlikely Possible in 3–5 years
3 Possible Likely within 2 years
4 Likely Expected this year
5 Almost certain Expected within months

Impact

Score Level Guide
1 Negligible Absorbed in normal operation
2 Minor Limited, contained
3 Moderate Material; management attention
4 Major Regulatory interest; significant harm
5 Severe Enforcement, serious harm, or existential

Rating = likelihood × impact. 1–4 Low · 5–9 Medium · 10–14 High · 15–25 Critical.

The register

ID Risk (cause → event → consequence) Category L I Rating Owner Treatment Target Residual Review
R-001 Because AI systems are procured without governance review, unassessed high-risk systems may go live, leading to regulatory breach and enforcement Compliance 4 4 16 [name] Mandatory intake gate; quarterly SaaS sweep 8 [date]
R-002 Because training data under-represents some groups, the model may produce discriminatory outcomes, leading to harm and legal claims Fairness 3 5 15 [name] Representativeness testing at G4; subgroup metrics 6 [date]
R-003 Because staff use unapproved AI tools, confidential data may be disclosed to third parties, leading to breach notification Security 4 4 16 [name] Approved tool list; DLP; training 8 [date]
R-004 Because vendors change models without notice, system behaviour may change silently, leading to undetected performance degradation Operational 3 3 9 [name] Contractual notification; output monitoring 4 [date]

Treatment options

Option When appropriate Record
Treat Reduce likelihood or impact The controls and their owner
Tolerate Within appetite Who accepted it, and when
Transfer Insurance or contract Note that accountability rarely transfers
Terminate Risk exceeds value The decision and rationale

Tolerating is a decision with a name on it

Accepted risk must record who accepted it and at what level of authority — see Decision Rights & Escalation. Risk that is tolerated by nobody in particular is risk that has simply been ignored.

Common AI risks to consider

Use as a prompt, not a checklist to copy:

  • Unassessed or unknown systems in production
  • Discriminatory outcomes for protected groups
  • Model drift degrading performance unnoticed
  • Over-reliance: humans rubber-stamping AI output
  • Confidential data leaked into external tools
  • Prompt injection or training-data poisoning
  • Vendor model change altering behaviour
  • Inability to explain a decision when challenged
  • Missing logs when evidence is needed
  • Key-person dependency on one ML engineer

Review

Level Cadence
Critical Monthly, at committee
High Quarterly
Medium Half-yearly
Low Annually

Adaptation notes

  • Small organisations: A 3×3 matrix and a single register covering all risk types is easier to sustain than a separate AI register nobody looks at.
  • Existing enterprise risk management: Do not create a parallel register. Add AI risks to the enterprise one with an AI tag, so they reach the board through the route that already works.
  • Regulated sectors: Align scales with your enterprise risk framework, and map risks to the regulatory obligations they threaten.

Not legal advice

These templates are a head start, not a substitute for professional judgement. Adapt them to your jurisdiction, sector, and risk appetite, and have qualified counsel review anything material before you rely on it.