Implementation and Self-Assessment Guide for Organizations
Singapore Β· Guideline Β· Personal Data Protection Commission Singapore and Infocomm Media Development Authority
Our summary
This guide helps organizations evaluate and implement responsible AI governance practices across internal structures, decision-making processes, operations management and stakeholder engagement. It accompanies the Model AI Governance Framework and provides questions, examples and practical references to enable organizations to assess how well their AI systems align with ethical principles. The guide is intended for private sector organizations deploying AI solutions at scale for customer-facing or operational purposes.
Written by the Index in our own words. It is not legal advice; the official text is the authority.
Inside this policy
Every section of this policy in order. Our notes summarise each one in plain language and do not quote the official text, which is the authority.
Drafted by the Index An automated summary of the official text, not yet reviewed by a person.Reviewed Checked by a person against the official text.
5 sections
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Section 1 Objectives of deploying AI
Guides organizations to incorporate ethical considerations when deciding whether to implement AI solutions. Organizations should clarify their business purpose, evaluate whether benefits in a responsible approach justify costs, and confirm alignment with organizational values and societal expectations.
Section 2 Internal governance structures and measures
Organizations should establish or adapt governance structures to oversee AI use, either by incorporating AI governance into existing governance, risk and compliance structures or creating dedicated committees, and should consider sandbox testing approaches and separation of oversight teams. Decision-making should be centralized for higher-risk or contentious AI deployments escalated to senior management, or decentralized using pre-approved and off-limits lists for lower-risk solutions, with boards managing risk and values, committees approving models, and project leads accountable for compliance and model risks. Personnel involved in AI governance must be aware of their roles and properly trained; staff handling AI systems need specialized training to interpret outputs and detect bias, all staff using AI should be aware of relevant risks and know where to escalate concerns, and organizations should consider hiring multi-disciplinary talent, creating specialized roles, and implementing education programs at all levels.
Section 3 Determining the level of human involvement in AI-augmented
Organizations should conduct impact assessments from technical and data protection perspectives to determine appropriate human involvement levels, choosing between human-in-the-loop when human judgment significantly improves decision quality, human-out-of-the-loop for high-volume micro-decisions with understandable explanations, or human-over-the-loop using confidence thresholds to trigger human intervention. When setting human involvement levels, organizations should consider risk appetite, user experience, and operational cost, and must continually review and mitigate risks post-deployment through regular model retraining, performance monitoring, data drift detection, and scenario response planning. For safety-critical systems, organizations must ensure personnel can assume control when necessary and the AI system provides sufficient information for informed decision-making and actions.
Section 4 Operations management
Organizations should implement accountability-based data management practices aligned with data protection laws, including tracking data lineage through provenance records and assessing third-party dataset risks. Organizations should verify dataset accuracy, completeness, credibility, currency and relevance; mitigate unintended bias by identifying sensitive data fields and checking for direct and indirect bias indicators; ensure datasets are fully representative by benchmarking against population statistics and using separate datasets for training, testing and validation; conduct statistical tests such as ROC curve analysis; and periodically review and update datasets using challenger models, adversarial models, or automated monitoring. Organizations should enable understanding of deployed models through explanation strategies such as surrogate models, sensitivity analysis, model reports, factsheets, simpler model versions, visualizations and narrative descriptions; when explainability cannot be practically achieved, use repeatability tests, counterfactual fairness testing, exception handling, time-sensitive model validation, error rate testing across subgroups, simulations, version control and model comparison.
Section 5 Stakeholder Interaction and Communication
Organizations should identify and communicate with internal and external stakeholders on AI solutions by tailoring explanations of data, models, human involvement, inferences, algorithms and impact to audience, purpose and context, customizing messages for different stakeholders, adjusting language and complexity, and charting stakeholder journeys to minimize information fatigue. Organizations should disclose to consumers the data fields important to decisions and their values, when and why and how AI was used, reasons for using AI, how models were trained and selected, risk mitigation steps, the role and extent of AI in decision-making in plain language and meaningful formats, outcomes of automated decisions with data sources and lineage, how data was trained and labelled, model performance statistics, and a policy on explanations; they should develop educational tools such as leaflets and user guides, test user interfaces for usability, and design them with users at the centre by consulting end users early and collecting feedback. Organizations must enable users to decline participation in AI solutions automatically or upon request and inform them of impacts, establish channels with trained personnel for users to submit feedback and questions, enable individuals to revise their personal data, set expectations for response times, publicize contact details such as a data protection officer, and create a mechanism allowing users to request reconsideration of consequential AI-based determinations affecting them potentially including procedures for appealing decisions and records of system interactions.
Controls
What this policy requires, forbids, grants or penalises, one control at a time and in our own words. Each control links to the official text, which is the authority. This is not legal advice.
Drafted by the Index Drafted automatically from the official text, not yet reviewed by a person.Reviewed Checked by a person against the official text.
Themes covered 10 of 35
Choose a theme to see only its controls. About the themes
Risk and scope 2 of 4
- Risk classification, not covered
- Prohibited practices, not covered
Data and privacy 1 of 4
- Data subject rights and consent, not covered
- Cross-border data transfer, not covered
- Copyright and training data, not covered
Transparency and records 3 of 4
- Labelling of synthetic content, not covered
Technical safeguards 2 of 4
- Bias and non-discrimination, not covered
- Testing and evaluation, not covered
Assurance and lifecycle 0 of 4
- Conformity assessment and certification, not covered
- Registration and notification, not covered
- Incident and breach reporting, not covered
- Post-market monitoring and corrective action, not covered
Rights and protected groups 0 of 4
- Automated decision-making rights, not covered
- Children and vulnerable groups, not covered
- Biometric identification and surveillance, not covered
- Whistleblowing, complaints and redress, not covered
Roles and organisation 2 of 6
- Supply chain and provider-deployer duties, not covered
- General purpose and foundation models, not covered
- Public sector use and procurement, not covered
- Innovation support and sandboxes, not covered
Enforcement and sectors 0 of 5
- Enforcement, penalties and regulators, not covered
- Sector rules: health, not covered
- Sector rules: finance and insurance, not covered
- Sector rules: employment, not covered
- Sector rules: education, not covered
The full list of controls could not be loaded, so only the first 31 are shown.
Section 1 6 controls
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Deployers should determine a specific purpose for implementing an AI system to address an identified problem or issue.
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Deployers should assess whether the expected benefits of deploying an AI solution in a responsible manner outweigh the costs, including consideration of a cost-benefit analysis.
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Deployers should confirm that a decision to use AI for a particular application is consistent with the organization's core values and societal expectations.
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Deployers should develop a set of ethical principles aligned with their organizational mission and applicable to their AI use.
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Deployers should consider leveraging benchmarks and case studies for comparable AI solutions and adopt relevant governance practices.
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Deployers should develop a Code of Ethics for AI use that addresses regulatory risks, reputational risks, costs, and internal resource commitments.
Section 2 5 controls
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Organizations should establish or adapt governance structures to oversee their use of AI.
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Organizations should consider establishing a multi-departmental committee with proper terms of reference to oversee AI governance and ensure compliance with commercial, legal, ethical and reputational requirements.
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Organizations should implement checks and balances through an internal oversight team and a separate validation team to review methodology, algorithms and deployment of AI.
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Organizations should ensure that AI governance processes verify compliance with applicable laws and regulations.
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Organizations should develop a handbook that documents the entire AI deployment governance process and make it available to all staff.
Section 3 7 controls
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Deployers should conduct an impact assessment measuring the probability and severity of harm to affected individuals and organizations from their AI system.
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Deployers should identify all internal and external stakeholders and assess how the AI solution affects them.
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Deployers should evaluate technical and personal data protection risks, including system integrity testing and data protection impact assessments.
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Deployers should assess societal and end-user risks by conducting testing with customer and community groups.
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Deployers should implement human-in-the-loop oversight when human judgment significantly improves decision quality or when subjective judgment is required.
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Deployers should implement human-out-of-the-loop processes for high-volume algorithmic decisions and ensure the AI system provides clear explanations of its recommendations.
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Deployers should implement human-over-the-loop approaches using statistical confidence thresholds to trigger human intervention when needed.
Section 4 5 controls
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Deployers should determine which data an AI system should access and which sensitive data it should not access.
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Deployers should implement measures to track data lineage including backward, forward and end-to-end data lineage.
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Deployers should develop and maintain data provenance records documenting the origins and history of data used in their AI systems.
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Deployers should create data inventories, data dictionaries, change processes and control mechanisms to document and manage data.
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Deployers should verify that data can be traced back to its source at each stage of processing.
Section 5 8 controls
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Organizations should identify all stakeholders, internal and external, who are involved in or affected by the deployment of an AI solution.
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Organizations should consider the purpose and context when deciding what explanations are needed for their AI solution.
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Organizations should customize communication messages and explanations for different stakeholders based on audience, purpose and context.
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Organizations should provide explanations at multiple levels covering data sources, model features, human involvement, algorithmic processes, and impact on users.
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Organizations should provide either process-based explanations about data and risk mitigation or outcome-based explanations about purpose and consequences, in language suited to each audience's technical level.
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Organizations should map the stakeholder journey and identify what information, at what level of detail and for what purpose should be disclosed at each significant milestone to prevent information overload.
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Organizations should inform relevant stakeholders that an algorithm is used in their products or services.
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Organizations should provide implicit explanations such as counterfactuals when technical explainability may not be useful to the audience.
Change history
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