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AI Is Already in Your Organization. The Question Is Whether You Are Governing It.

Beverly Brooks Thompson lays out seven questions every leadership team should be able to answer about how AI is being used and governed inside their organization.

Beverly Brooks Thompson, PhD, CFRE

Artificial intelligence is moving faster than most organizations' governance structures. Employees are experimenting with generative AI. Vendors are embedding AI into products organizations already use. HR teams are considering AI for recruiting. Finance teams are using automation. Marketing teams are generating content. Executives are increasingly using AI to summarize information and support decisions.

In many organizations, all of this is happening before leadership has answered a more fundamental question: Who is responsible for governing AI?

That may be the most important governance question facing organizations today. The National Association of Corporate Directors, NIST, SHRM, and AICPA have reached a consistent conclusion across their respective guidance: AI governance cannot belong solely to information technology. It is an enterprise leadership responsibility.

Seven Questions Your Leadership Team Should Be Able to Answer Right Now

If your leadership team cannot confidently answer these questions, your organization does not yet have an AI governance framework, and that gap is creating risk every day AI is in active use.

The 7 Governance Questions

  1. What AI are we already using, including what vendors have built into tools we already rely on?
  2. What organizational or personal data is entering those systems, and where does it go?
  3. Which AI uses could materially affect people, money, safety, reputation, or strategic decisions?
  4. Who has the authority to approve new AI applications?
  5. How are we evaluating AI vendors and the AI capabilities embedded in existing software?
  6. Which existing policies, including HR, cybersecurity, privacy, finance, and communications, need to change because of AI?
  7. Who is accountable for reporting AI risk to the CEO, and when applicable, to the board?

Five Issues Requiring Immediate C-Suite Attention

  1. Data Privacy and Cybersecurity. What information are employees putting into AI systems, and where does that information go? Employees can unintentionally expose confidential business information, financial data, or client records simply by entering it into an unapproved application. Leaders must understand what vendors are doing with their data: whether it can be retained, used to train future models, or accessed by third parties.
  2. Accuracy, Bias, and the Loss of Human Judgment. AI can generate an answer that sounds authoritative and is completely wrong. It can also reproduce bias embedded in training data, which becomes serious when AI influences hiring, performance evaluation, financial reporting, or customer decisions. The governance principle is straightforward: AI may inform a decision. It should not eliminate accountability for the decision. A human being must remain responsible.
  3. Shadow AI and Third-Party Risk. Most organizations have more AI operating inside them than senior leadership realizes. Shadow AI occurs when employees adopt tools without formal review. Embedded AI occurs when vendors add AI capabilities to products already in use. You cannot govern what you do not know exists. Organizations need an active AI inventory, not simply an approved list posted somewhere that nobody updates.
  4. Workforce Use, Skills, and Accountability. AI governance is not primarily a software problem. It is a people problem. Every employee needs to understand the rules: which tools are approved, what information they may enter, when human review is required, and where to go when they are unsure. Policies without practical employee guidance create the illusion of governance without the reality of it.
  5. Accountability and Decision Rights. When something goes wrong with AI, who owns the problem? If the answer is unclear today, it will be even less clear during an incident. Effective governance assigns decision rights before something goes wrong, not after.

What a Practical Governance Framework Looks Like

Governance does not have to begin with a 100-page policy manual. A practical framework starts with three layers: an enterprise AI governance policy establishing authority, accountability, and acceptable use; operational governance tools that translate policy into actual decisions (an AI inventory, an intake process, a vendor due-diligence checklist); and updates to the policies that already exist across HR, cybersecurity, privacy, finance, and communications to address AI-specific responsibilities.

Organizations with governing boards should ensure directors understand how AI supports organizational strategy, where it creates material risk, and who has executive accountability. Organizations without a traditional board should create an internal AI Governance Council, composed of representatives from executive leadership, IT, legal, HR, finance, and major business units, to fulfill the essential oversight functions.

The goal is not to adopt AI everywhere. The goal is to use AI where it creates meaningful value, with clear ownership, trusted data, appropriate safeguards, and the ability to adapt as technology evolves.

AI is already changing your organization. The governance question is whether leaders will shape that change deliberately, or discover later that it shaped the organization for them.

Working with Pellerin Technology

Pellerin Technology has built AI governance frameworks for organizations ranging from healthcare systems to nonprofit institutions to mid-market enterprises. If your leadership team is ready to answer the seven questions above, and build the structure to act on the answers, we can guide that process from assessment through implementation.

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