Governing AI Development
Domain III asks: how do you govern the people, processes, and decisions that build AI systems? Governance must be embedded at every stage of development — not retrofitted after deployment.
The Core Principle: AI governance is not a compliance checkbox at the end — it is a continuous practice woven through every development decision. The earlier governance is applied, the cheaper and more effective it is. A bias caught in the data collection phase costs far less to fix than one discovered after deployment at scale.
AI Development Lifecycle — Governance at Every Stage
Four Governance Domains in AI Development
| Topic Area | Key Concepts |
|---|---|
| Data governance for AI | Data quality dimensions, data provenance, data lineage, training data documentation (Datasheets for Datasets) |
| Bias identification & mitigation | Pre-processing, in-processing, post-processing approaches; fairness metrics; demographic parity |
| Model documentation | Model Cards — intended use, performance across groups, limitations; technical documentation |
| Privacy & security by design | 7 Privacy by Design principles; differential privacy; federated learning; data minimization in AI |
| Human oversight | HITL vs HOTL vs HIC; meaningful human review; override capabilities |
| Testing & evaluation | Fairness testing, adversarial testing, red teaming, shadow deployment, A/B testing |
| Supply chain & third-party AI | Open source risks, model provenance, vendor governance, inherited bias |
| Model drift | Data drift vs concept drift; monitoring triggers; retraining thresholds |
Data Governance for AI
AI models are only as good as the data they are trained on. Data governance for AI encompasses the policies, practices, and controls that ensure training data is high quality, representative, legally compliant, and well-documented.
Why Data Governance is Different for AI: Traditional data governance focuses on operational data. AI data governance adds unique challenges: training data can encode historical discrimination, data collected for one purpose may not be valid for training, and the relationship between data quality and model behavior is often opaque.
Data Quality Dimensions
Bias in Training Data — Three Mitigation Stages
Fairness Metrics — Key Definitions
| Metric | Definition | Exam Hook |
|---|---|---|
| Demographic Parity | The positive outcome rate is equal across demographic groups regardless of qualifications | Also called "statistical parity" — equal selection rates |
| Equal Opportunity | Among qualified individuals, the true positive rate is equal across groups | Focuses on not missing qualified people from any group |
| Equalized Odds | Both true positive rate AND false positive rate are equal across groups | Strongest fairness constraint — hardest to satisfy simultaneously |
| Individual Fairness | Similar individuals receive similar predictions regardless of group membership | Contrast with group fairness — focuses on like-for-like treatment |
| Calibration | Among individuals predicted at 70% probability, 70% actually have that outcome — across all groups | Recidivism tool COMPAS controversy: calibrated but racially biased in error rates |
Data Provenance: The origin, source, and chain of custody of training data — where it came from, how it was collected, what transformations were applied, and whether the collection was lawful and consented.
Data Lineage: The end-to-end flow of data through the AI pipeline — from ingestion through transformations, feature engineering, and into the model. Enables traceability and auditability.
Both are required for AI accountability — if a model produces a biased output, data provenance and lineage enable the governance team to trace the bias back to its source.
AI systems increasingly rely on third-party components: pre-trained foundation models, open-source libraries, external datasets, and API-based AI services. Each component introduces supply chain risk.
Key risks: Inherited bias from upstream training data; unknown provenance of pre-trained weights; security vulnerabilities in dependencies; intellectual property and licensing issues with open-source models; vendor lock-in limiting future governance control.
Governance response: AI Bill of Materials (AI-BOM) documents all components; vendor due diligence assessments; contractual data governance obligations for third-party providers.
Model Development Controls
Good AI governance requires standardized documentation, built-in privacy and security protections, meaningful human oversight, and rigorous testing before any model reaches users.
Documentation as Governance: Model Cards and Datasheets for Datasets are not just paperwork — they are the primary mechanism for communicating AI system characteristics to deployers, regulators, and affected communities. Without them, accountability is impossible.
Model Cards vs Datasheets for Datasets
- Motivation — why was this dataset created?
- Composition — what is in it? Size? Demographics?
- Collection process — how was data obtained?
- Preprocessing — what cleaning was applied?
- Uses — recommended and prohibited use cases
- Distribution — how is it licensed and shared?
- Maintenance — who maintains it going forward?
- Model details — type, training approach, version
- Intended use — primary use cases and out-of-scope uses
- Factors — relevant demographic or contextual factors
- Metrics — performance measures used
- Evaluation data — what data was used to test?
- Quantitative analyses — performance disaggregated by group
- Ethical considerations and caveats
Human Oversight Tiers
Privacy by Design — 7 Foundational Principles
Developed by Dr. Ann Cavoukian, former Ontario Privacy Commissioner. Embedded in GDPR and referenced in AI governance frameworks globally.
Privacy-Preserving AI Techniques
Mathematical guarantee that the model's outputs are not significantly affected by any single individual's data. Noise is added during training to prevent inference of individual records.
Trade-off: More privacy = less accuracy. The privacy budget (ε) controls this balance.
Model training occurs locally on individual devices or nodes. Only model updates (gradients) — not raw data — are shared with a central server. Raw personal data never leaves its source.
Use case: Keyboard prediction on mobile phones (Google Gboard); medical AI across hospitals without sharing patient records.
Anonymization: Irreversibly removes identifiers — data can no longer be linked to individuals. Removes from GDPR scope (if truly achieved).
Pseudonymization: Replaces direct identifiers with pseudonyms. Re-identification still possible with additional data. Still subject to GDPR.
Accountability & Auditing
How do you verify that an AI system is behaving as intended, is fair, and does not cause harm? This tab covers the testing and evaluation practices that make AI systems accountable — before and after deployment.
Accountability Requires Evidence: You cannot claim your AI is fair, safe, or compliant without testing it. The governance practices in this tab — red teaming, algorithmic auditing, testing regimes — are what transform governance principles into verifiable claims.
- Structured adversarial testing by a dedicated team attempting to find failures, harms, and vulnerabilities
- Simulates how bad actors or edge-case users might misuse the system
- Tests for both safety failures (harmful outputs) and security failures (prompt injection, model extraction)
- Required for GPAI with systemic risk under the EU AI Act
- Can be internal, external, or a combination (e.g., third-party red team firms)
- Jailbreaking: bypassing safety filters through prompt manipulation
- Prompt injection: inserting instructions that override system prompts
- Bias elicitation: prompts that reveal discriminatory outputs
- Hallucination: inducing confident false statements
- Privacy leakage: extracting training data or PII from the model
- Harmful content: generating dangerous, illegal, or hateful outputs
Testing Types for AI Systems
Algorithmic Auditing
First-party (internal): Conducted by the organization that built or deploys the AI. Lowest independence but deepest access to the system.
Second-party (regulatory): Conducted by a regulator or government authority. Required for high-risk AI under the EU AI Act (conformity assessment) and financial sector AI (model risk management).
Third-party (independent): Conducted by external auditors with no stake in the outcome. Highest independence; growing field of algorithmic audit firms.
Effective audits require: access to training data, model architecture, testing results, documentation, and deployment context — not just the model output alone.
The US Federal Reserve's Supervisory Guidance on Model Risk Management (SR 11-7, 2011) established principles for governing AI/ML models in financial institutions — predating the AI governance field by a decade.
Key SR 11-7 principles: Model validation by independent parties; conceptual soundness assessment; outcome analysis; ongoing monitoring; model inventory.
These financial sector principles have strongly influenced AI governance frameworks broadly — the emphasis on independent validation, documentation, and ongoing monitoring appear throughout NIST AI RMF and ISO/IEC 42001.
| Drift Type | What Changes | Example | Governance Response |
|---|---|---|---|
| Data Drift | Distribution of input data changes from training data | Fraud patterns change; demographics of users shift | Monitor input distributions; set drift thresholds; trigger review |
| Concept Drift | Relationship between inputs and the target outcome changes | COVID changed what "healthy" baseline looks like; economic shift changes credit risk | Monitor outcome metrics; compare predictions vs actual outcomes; scheduled retraining |
| Prediction Drift | Model's output distribution changes without input distribution change | Model begins approving more loans without clear cause | Monitor output distributions; alert on threshold breach |
| Label Drift | Ground-truth labels themselves change in meaning or prevalence | Regulatory change redefines what counts as a "suspicious transaction" | Update ground truth; re-evaluate; consider full retraining |
Practice Quiz — Domain III
Test your knowledge of AI development governance. Select the best answer for each question.
Memory Hooks
Mental models and mnemonics for the Domain III concepts most likely to appear on exam day.
| Artifact / Practice | Type | When Applied | Key Purpose |
|---|---|---|---|
| Datasheet for Datasets | Documentation | Data collection/prep (Stage 2–3) | Transparency about training data provenance and characteristics |
| Model Card | Documentation | Post-training evaluation (Stage 5) | Transparency about trained model performance, limitations, and ethics |
| DPIA | Assessment | Before processing begins (Stage 1) | Evaluate high risks to individuals' rights under GDPR Art 35 |
| Red Teaming | Testing | Pre-deployment (Stage 5) | Adversarially identify failures, harms, and vulnerabilities |
| Shadow Deployment | Testing | Pre-deployment (Stage 5–6) | Compare new model to existing on real traffic without user exposure |
| HITL / HOTL | Oversight | Deployment & operation (Stage 6–7) | Maintain human control over AI decision-making |
| Drift Monitoring | Monitoring | Post-deployment (Stage 7) | Detect performance degradation from changing data or concepts |
Flashcards & Study Advisor
Tap any card to flip it. Use the advisor panel for targeted study guidance by topic.
Flashcards — Domain III Key Concepts
What are the 3 bias mitigation stages and when does each intervene?
Pre-processing = fix training DATA before training. In-processing = constrain ALGORITHM during training. Post-processing = adjust OUTPUTS after prediction.
Model Card vs Datasheet for Datasets — what does each document?
Datasheet for Datasets (Gebru et al.) = documents TRAINING DATA (provenance, composition, collection). Model Card (Mitchell et al.) = documents the TRAINED MODEL (intended use, performance by group, limitations).
HITL vs HOTL vs HIC — what distinguishes each tier?
HITL = human approves EACH decision BEFORE action. HOTL = AI acts autonomously; human monitors and can intervene. HIC = human holds strategic/organizational control over AI systems.
Name the first 2 (most tested) Privacy by Design principles.
1) Proactive not reactive — prevent privacy harms before they occur. 2) Privacy as default — maximum protection automatically, no user action required.
Data drift vs Concept drift — what is the difference?
Data drift = input distribution changes (different people/patterns than training). Concept drift = the RELATIONSHIP between inputs and the outcome changes (same inputs now mean something different).
What is shadow deployment and how does it differ from A/B testing?
Shadow deployment: new model receives real inputs but outputs are NOT shown to users — captured for offline comparison. Zero user risk. A/B testing: both models serve real users and their outputs are compared. Some user exposure.
What is federated learning and what privacy problem does it solve?
Training occurs LOCALLY on devices/nodes — only model updates (gradients) are shared centrally, never raw personal data. Solves: training on sensitive data (medical, financial) without centralizing it. Used in Google Gboard, medical AI research.
What is "inherited bias" when using a third-party foundation model?
Biases encoded in the foundation model's training data or architecture carry into fine-tuned products. The deploying organization typically bears responsibility for output harms — even if the bias originated upstream. Requires vendor due diligence and bias testing.
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Data Governance — Exam Focus Points
- Data quality dimensions most tested: accuracy, completeness, representativeness, and timeliness. Know how each affects model fairness and reliability.
- Representativeness is the dimension most specific to AI — training data must reflect the diversity of the real-world population the model serves.
- Distinguish data provenance (where did this data come from?) from data lineage (how did data flow through the pipeline?). Both enable traceability.
- AI supply chain risk is a growing exam focus — using third-party models, open source libraries, and external datasets all introduce inherited bias, security vulnerabilities, and governance gaps.
- Know what an AI Bill of Materials (AI-BOM) is — a complete inventory of all components in an AI system, analogous to a software bill of materials (SBOM).
- Training data collected for one purpose cannot simply be reused to train an AI model without a legal basis under GDPR's purpose limitation principle (Art 5).
Bias Mitigation — Exam Focus Points
- The three-stage framework (pre/in/post) is the most tested topic in Domain III. Know the stage name, when it intervenes, and 2–3 techniques for each.
- Pre-processing techniques: resampling (oversample underrepresented groups), reweighting (higher loss weight for minority examples), data augmentation (add synthetic samples).
- In-processing techniques: adversarial debiasing (adversary tries to predict protected attribute — main model is penalized when it succeeds), fairness regularization in the loss function.
- Post-processing techniques: threshold adjustment (different decision thresholds by group to achieve equalized odds), calibration adjustment.
- Know the fairness metric definitions: demographic parity (equal selection rates), equalized odds (equal TPR and FPR across groups), individual fairness (similar treatment for similar individuals).
- The COMPAS recidivism tool controversy is a canonical case study: the tool was calibrated (accurate on aggregate) but had racially disparate false positive rates — illustrating that multiple fairness metrics can conflict.
Model Documentation — Exam Focus Points
- The most common exam trap: confusing Model Cards and Datasheets for Datasets. Remember: Model Card → trained MODEL. Datasheet → training DATASET.
- Model Cards (Mitchell et al., Google, 2019): document intended use, out-of-scope uses, factors, metrics, evaluation data, and performance disaggregated by group.
- Datasheets for Datasets (Gebru et al., 2018): document motivation, composition, collection process, preprocessing, uses, distribution, and maintenance.
- Both are referenced in the EU AI Act's technical documentation requirements for high-risk AI and in ISO/IEC 42001.
- System Cards (Meta) extend Model Cards to multi-component AI systems with multiple models and interfaces — an evolution beyond single-model documentation.
- Documentation is not a one-time activity — both Model Cards and Datasheets must be updated when models are retrained or datasets are modified.
Oversight & Privacy — Exam Focus Points
- HITL, HOTL, and HIC are frequently tested — know the precise definition and a concrete use case for each.
- HITL: human approval BEFORE each AI decision. Slowest, highest control. Example: radiologist reviewing AI scan results before clinical action.
- HOTL: AI acts first, human monitors in real time and can interrupt. Example: autonomous trading with a human kill-switch watching P&L.
- The EU AI Act's human oversight requirement for high-risk AI generally requires HITL or HOTL — not just HIC.
- For Privacy by Design, the two most-tested principles are #1 (Proactive) and #2 (Privacy as Default). Know all 7 in order.
- Federated learning and differential privacy are the two most-tested privacy-preserving AI techniques. Federated learning = train locally; differential privacy = add mathematical noise to prevent individual inference.
- Differential privacy's privacy budget (ε): lower ε = more privacy, less accuracy. Higher ε = less privacy, more accuracy. This is a fundamental trade-off.
Testing & Auditing — Exam Focus Points
- Red teaming = structured adversarial testing BEFORE deployment. Focus areas: jailbreaking, prompt injection, bias elicitation, hallucination, privacy leakage, harmful content.
- Shadow deployment vs A/B testing: shadow = new model hidden, zero user exposure. A/B = both models serve real users. Shadow is lower risk; A/B provides real behavioral data.
- Know the three types of algorithmic audits by party: first-party (internal, deep access), second-party (regulatory), third-party (independent, highest credibility).
- SR 11-7 (Federal Reserve, 2011) is AI governance's oldest ancestor — model validation, independent review, ongoing monitoring. Know that it predates modern AI governance but heavily influenced it.
- Model drift monitoring: data drift = input distribution changes; concept drift = outcome relationship changes. Both require monitoring thresholds and retraining triggers.
- Technical debt in AI governance: shortcuts during development (skipped documentation, inadequate testing) compound into governance failures post-deployment — harder and costlier to fix than if addressed early.