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• Analyze the root cause and act to prevent recurrence.
• Document the lesson and update the testing, the policy, and the training.

8.7 Data, Security, Vendors, and Agents: Governing the Capability, Not the Interface

◆ Key idea: govern the capability, not the interface.
The question is not which product was approved. It is what data the system may reach,
what actions it may take, whose identity it uses, and what evidence exists afterwards.

Chapter Four explained the rules of safe use at the level of the individual and the task. Here
we raise the level to the organization: who approves types of data? How are permissions

distributed? What are the contractual requirements? And who monitors the changes? Risk
does not come from the model alone, but from the whole system: the data sources, the
open components, the extensions, the interfaces, the tools the system can call, and the

people who hold access.

In assessing a vendor, it is not enough to ask whether the service is secure. Provable answers
are required: are the inputs used for training? Where is the data stored? What is the
retention period? Who are the sub processors? How are encryption keys managed? Are

there logs and identity management? How does the vendor announce a model update or a
change of terms? Does it allow data export and deletion? What are the audit rights and the
incident notification duties?

TABLE 8-8: VENDOR AND CONTRACT REVIEW BEFORE ADOPTION

Area The question that must be answered

Purpose of For what purpose is our data processed, and is it used for
processing training?

Location and Where is the data stored, for how long, and under which

retention jurisdiction?

Sub processors Who else touches the data, and are we notified of changes?

Access and identity How is access controlled, logged, and reviewed?

Change How are model or term changes announced, and how long is the
management notice?

Incidents What must the vendor tell us, and within what time?

Export and deletion Can we retrieve our data and templates, and have them deleted?

Exit What is the transition path, and has it been tested?

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