ISO 42001: Controls, Evidence, and Audit Readiness

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Written by Emily Hilton

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We at GSDC are dedicated to giving you one-of-a-kind, expert-led learning experiences that are a key element of your education. 

 

Our Mentor Connect seminars equip professionals with the knowledge and hands-on experience they need to succeed in the AI-driven future.

 

At our most recent GSDC Mentor Connect event, "ISO 42001: Controls, Evidence, and Audit Readiness," we discussed how businesses can leverage the requirements of ISO 42001 to establish effective controls and maintain their documents in readiness for an audit. 

 

These sessions are an important part of our certification programs since they teach professionals how to use and maintain Artificial Intelligence Management Systems (AIMS) in the right way.

What is ISO 42001 and Why Does It Matter?

The first international standard for Artificial Intelligence Management Systems (AIMS) is ISO 42001:2023. This new standard gives businesses a way to ethically, openly, and accountably create, use, and maintain AI systems.

 

The standard answers important concerns that customers, regulators, and other interested parties are asking more and more: Is the AI fair? Is it safe? Is it right? 

 

ISO 42001 accreditation gives organisations that are making AI solutions independent, verifiable proof that they are following responsible AI governance.

Real-World Success: The Cresta Case Study

 

During our session, we examined how Cresta, a leader in AI-driven customer experience solutions, successfully achieved ISO 42001 certification. 

 

Cresta's journey illustrates a fundamental truth: building powerful AI alone isn't enough in today's regulatory environment.

 

Cresta handles millions of sensitive customer conversations daily through their AI-powered contact center solutions. 

 

They realized that making public promises about responsible AI wasn't sufficient; they needed independent, verifiable proof of their governance, ethics, and security practices. 

 

This commitment drove them to pursue ISO 42001 certification, embedding responsible AI into every layer of their operations, processes, and culture.

From Requirements to Controls: The Translation Process

 

The core challenge in ISO 42001 implementation lies in translating broad requirements into practical controls. 

 

The standard provides requirements in general terms, but organizations must convert these into specific, measurable controls and then demonstrate them with concrete evidence during audits.

The Three Pillars of ISO 42001 Controls

1. Governance Controls

 
  • Establishing AI Ethics Boards or Governance Committees
  • Implementing decision-logging systems for major AI-related choices
  • Creating charter documents and terms of reference
  • Maintaining meeting minutes that show ethical deliberations
  • Securing signed approvals for high-risk AI deployments
 

2. Technical Controls

 
  • Conducting bias testing before deploying machine learning models
  • Implementing continuous monitoring dashboards for drift, accuracy, and anomalies
  • Generating test reports showing bias analysis
  • Maintaining logs from monitoring tools
  • Creating incident tickets that document corrective actions
 

3. Organizational Controls

 
  • Developing regular training and awareness programs on AI risks, ethics, and compliance
  • Establishing clear AI Policies and enforcement mechanisms
  • Maintaining training attendance records and assessment results
  • Publishing signed "Responsible AI Policy" documents
  • Keeping HR records that demonstrate policy enforcement

The Four Types of Evidence Auditors Expect

 

Understanding what auditors look for is crucial for AIMS developmental assessment and maintaining compliance. During our session, we identified four critical categories of evidence:

1. Policy-Based Evidence

 

Documents that establish rules, principles, and expectations:

 
  • AI ethical use policies
  • Governance charters
  • Data retention policies

2. Process-Based Evidence

 

Proof that processes are actively followed, not just documented:

 
  • Meeting minutes
  • Risk registers
  • Signed approvals

3. System/Technical Evidence

 

Objective, machine-generated proof of system functionality:

 
  • Monitoring logs
  • Test results
  • Performance dashboards

4. Competence Evidence

 

Demonstration of proper skills and awareness:

 
  • Training attendance records
  • Certification records
  • Signed policy acknowledgments

Best Practices for Audit Readiness

Centralized Repository Management

 

Scattered evidence creates panic during audits. Organizations should establish a single, structured location for all documentation using document management systems like SharePoint, Confluence, or specialized GRC tools. This approach reduces stress, saves time, and ensures consistency.

Version Control and Updates

 

Auditors expect to see living documents, not outdated policies. Effective version control includes:

 
  • Assigning clear version numbers (v1.0, v1.1, etc.)
  • Maintaining approval trails showing who updated what and when
  • Conducting annual reviews of critical documents

Evidence Ownership Assignment

 

Clear ownership prevents delays and confusion during audits. Best practices include:

 
  • Assigning specific control owners (e.g., Risk Register → Risk Manager)
  • Using RACI matrices (Responsible, Accountable, Consulted, Informed)
  • Tracking ownership in centralized repositories

Continual Audit Readiness

 

Rather than treating audits as annual "exam cram" sessions, organizations should:

 
  • Schedule quarterly internal mini-audits
  • Automate evidence collection where possible
  • Build audit-readiness into daily workflows

Key Questions from Our Session

 

During the session, participants raised several insightful questions that highlighted real-world implementation challenges:

 

"How do we maintain evidence integrity across different AI projects?" This question led to a discussion about creating standardized evidence templates and ensuring consistency across multiple AI initiatives within an organization.

 

"What's the difference between compliance and actual responsible AI practice?" We explored how ISO 42001 goes beyond mere checkbox compliance, requiring organizations to embed responsible AI principles into their operational DNA.

 

"How often should we update our AI Policies and risk assessments?" The session emphasized the dynamic nature of AI risks and the need for regular policy updates, typically on a quarterly basis or whenever significant changes occur in AI systems.

The Path Forward: Becoming ISO 42001 Ready

To successfully apply ISO 42001, you need to do more than just grasp the standard. You also need to change the way you think about AI governance to be based on evidence. 

 

Companies need to go beyond making vague promises about responsible AI to putting in place real controls that auditors can check.

 

The framework we talked about, Requirement → Control → Evidence, makes it easy for businesses to stay compliant. Companies may show that they are committed to responsible AI by putting in place strong governance controls, technical safeguards, and organisational skills.

 

As more and more businesses start using AI, being able to show that you handle it responsibly through ISO 42001 certification becomes not only a competitive edge but also a must-have for your organisation. 

 

Companies that learn this standard now will be better able to deal with the complicated rules and regulations of the future.

Conclusion

ISO 42001 represents more than a compliance framework; it's a roadmap for building trust in AI systems. 

 

Through proper controls, comprehensive evidence collection, and continuous audit readiness, organizations can demonstrate their commitment to responsible AI development and deployment.

 

The insights from Cresta's journey and the practical frameworks discussed in our session provide a clear blueprint for success. 

 

As AI continues to transform industries, the organizations that thrive will be those that can prove, not just promise, their commitment to responsible AI practices.

 

Ready to master ISO 42001 and elevate your AI governance capabilities? 

 

Join our GSDC certification program and gain the expertise needed to lead responsible AI implementation in your organization. Enroll today and take the first step toward becoming an ISO 42001 expert!

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Emily Hilton

Learning advisor at GSDC

Emily Hilton is a Learning Advisor at GSDC, specializing in corporate learning strategies, skills-based training, and talent development. With a passion for innovative L&D methodologies, she helps organizations implement effective learning solutions that drive workforce growth and adaptability.

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