Model Artificial Intelligence Governance Framework
Singapore Β· Guideline Β· Personal Data Protection Commission (PDPC)
Our summary
This is a practical guide for organisations to implement responsible AI deployment across four main areas: governance structures, human involvement in algorithmic decision-making, operations management, and stakeholder communication. The framework is technology and sector agnostic, designed to be applicable to organisations of any size, and translates AI ethical principles into actionable measures that organisations can adopt.
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 Our notes summarise each one in plain language and do not quote the official text, which is the authority.
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12 sections
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2 Introduction
3 sections
This section introduces the Model Framework by outlining its objectives, underlying assumptions, and key definitions used throughout the document.
Objectives
This voluntary Model Framework guides organisations deploying AI at scale to do so responsibly by tailoring measures to address identified risks based on factors including the type and sophistication of AI systems, the degree of autonomous versus augmented decision-making, and the severity and likelihood of impact on individuals, aiming to build stakeholder trust through responsible practices and alignment with accountability standards such as Singapore's PDPA and OECD Privacy Principles. The Framework rests on two main principles: organisations using AI in decision-making must strive to ensure their processes are explainable, transparent and fair to the extent possible, and AI solutions must be human-centric by prioritising the protection of human interests, well-being and safety during design, development and deployment. Organisations deploying AI at scale should detail their ethical principles and incorporate them into their existing corporate values and governance structures.
Assumptions
The framework applies mainly to machine learning models, does not address cyber-attack risks, and does not replace compliance with existing laws including sector-specific regulations in finance, healthcare and legal sectors. Adopting it will support organisations in demonstrating accountability-based practices but cannot substitute for compliance with sector-specific requirements.
Definitions
This section defines key terms including AI as technologies simulating human traits to produce outputs or decisions, AI Solution Providers as entities developing AI systems, Organisations as entities deploying such systems, and Individuals as persons who use or may be affected by AI products and services.
3 Model AI governance framework
4 sections
The framework covers four key areas: internal governance structures adapted to handle algorithmic decision-making; determining appropriate human involvement levels; operations management for developing and maintaining AI models; and stakeholder communication strategies. Organisations can adapt the flexible framework to apply only relevant elements.
Internal Governance Structures and Measures
Organisations should develop internal governance structures that provide appropriate supervision and control over AI introduction and use, which can adapt existing frameworks or establish new ones such as AI risk management within enterprise risk management or ethics review boards, with essential support from top management and the board. Key responsibilities include applying risk control measures to assess and manage AI deployment risks including potential adverse impacts on vulnerable individuals, determining appropriate human involvement levels, managing model training and selection, establishing monitoring and reporting systems to track deployed AI performance, ensuring knowledge transfer during personnel changes, reviewing governance structures during organisational or staffing changes, assessing training datasets for inaccuracy and bias, and providing staff with role-appropriate training. Organisations should periodically review their internal governance structures and measures to maintain relevance and effectiveness, and can establish governance through multi-stakeholder decision-making bodies such as research boards and architecture steering groups with clearly defined roles, comprehensive employee ethics codes and training, or appointing a council with representatives from data, privacy, security and business teams to review high-risk AI implementations, with risk management processes to assess and identify risks in AI projects where high-risk projects are referred for review and low-risk projects proceed directly to development.
Determining the Level of Human Involvement in AI-augmented Decision-making
Organisations should clarify commercial objectives for using AI, weigh them against decision-making risks guided by corporate values and societal norms, continually identify and review risks with documented impact assessments and mitigation plans. The framework identifies three human oversight approaches - human-in-the-loop (AI provides recommendations with human full control), human-out-of-the-loop (AI has full control without human override), and human-over-the-loop (humans monitor and can take control at unexpected events) - with a probability-severity matrix helping determine appropriate involvement levels, though nature of harm, reversibility, and operational feasibility should also be considered. For safety-critical systems, humans must be able to assume control with AI providing sufficient information for meaningful decisions or safe shutdown; organisations should further evaluate domain knowledge requirements and compliance costs, typically requiring human-in-the-loop for high non-compliance scenarios and allowing human-out-of-the-loop for high-volume low-harm transactions, with continuous model performance monitoring in both cases.
Operations Management
Organisations must establish data accountability practices covering data lineage tracking, quality assessment across eight dimensions, and bias mitigation through heterogeneous and complete datasets with separate training, testing and validation datasets tested for systematic bias across demographic groups; they must periodically review and update these datasets while recognising selection bias (from unrepresentative training data) and measurement bias (from skewed collection devices), and may incorporate new production data while considering reinforcement bias. Organisations must proactively de-bias models using objective data, testing against diverse demographic datasets and ensuring the four-fifths rule where protected group selection rates reach at least eighty percent of the majority group rate, then test for adverse impact post-deployment and adjust if bias is detected. Using a risk-based approach to prioritise transparency measures, organisations must implement explainability (describing algorithm function and prediction use), repeatability (result consistency in live environments), and regular tuning as core practices, while reserving reproducibility (independent teams achieving same results), traceability (documenting decisions, datasets and processes), and auditability (readiness for internal or external assessment) for specific scenarios; explainability may be omitted where disclosure could enable bad actors to avoid detection or expose confidential information, and supplementary tools like surrogate models or counterfactual explanations may assist.
Stakeholder Interaction and Communication
Organisations should share information about their use of AI in products and services, including what AI is, how it affects consumers, and risk management steps, with tailored communication and explanations of how AI works and its consequences for different stakeholder groups. Organisations should address consumer information needs throughout the customer journey from awareness through decision review, considering factors like risk, reversibility, alternatives, costs, system complexity and technical feasibility when deciding whether to provide opt-out options, and offering recourse channels such as decision review if opt-out is not provided. Organisations should establish feedback and decision review channels, test user interfaces before deployment, communicate in easy-to-understand language, may implement acceptable user policies to prevent malicious manipulation, should obtain detailed information from AI solution providers about data sources, model training, human involvement and bias mitigation measures, design AI systems through user research and human-centric principles, and disclose when an AI system is in operation and its development status.
Annex A For Reference: A Compilation of Existing AI Ethical Principles
This annex compiles foundational AI ethical principles from multiple sources that organizations may adopt, covering accountability for system functioning, accuracy in identifying error sources, auditability through disclosure, explainability to users in non-technical language, fairness to prevent discrimination across demographics, human centricity to distribute benefits equitably and maintain user control over data, alignment with human rights, inclusivity to ensure accessibility, progressiveness favoring valuable implementations, responsibility and transparency with redress mechanisms, security against tampering, and sustainability for beneficial long-term insights. Records of design and decision-making should be maintained.
Annex B Algorithm Audits
1 section
Algorithm audits are conducted to discover actual algorithm operations, typically at a regulator's request or by AI providers helping customers respond to regulatory requirements. Before conducting an audit, organisations should consider whether sufficient information has already been provided through technical documentation and records, and should weigh audit costs and time against expected investigative benefits.
Acknowledgements
This section acknowledges organizations and individuals who provided feedback during development of the framework. The publication is intended to encourage responsible artificial intelligence development and adoption, and is not a legal authority or substitute for professional advice; the PDPC and its staff disclaim liability for any errors or reliance on the contents.
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 9 of 35
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Risk and scope 1 of 4
- Risk classification, not covered
- Prohibited practices, not covered
- Impact assessment, 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 2 of 4
- Labelling of synthetic content, not covered
- Technical documentation, not covered
Technical safeguards 3 of 4
- Accuracy, robustness and cybersecurity, 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
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Internal Governance Structures and Measures 6 controls
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Organisations should build or adapt internal governance systems to oversee the use of AI in their business and service delivery.
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Organisations should assign roles and responsibilities clearly to personnel and departments overseeing different stages of AI deployment.
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Organisations should ensure that staff responsible for AI governance receive proper training, are aware of their duties, and are given adequate resources and guidance.
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Organisations may use ethics review boards or similar structures to manage ethical considerations as part of their governance.
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Organisations may adopt centralised or decentralised governance mechanisms depending on what is appropriate for their structure and culture.
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Top management and board members should actively support, sponsor and participate in the organisation's AI governance efforts.
Determining the Level of Human Involvement in AI-augmented Decision-making 4 controls
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Organisations should first establish their business reasons for using AI before determining how much human oversight to apply in AI-assisted decisions.
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Organisations should evaluate their business objectives for using AI against the risks it poses, guided by their corporate values and local societal expectations.
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Organisations should document any gaps between AI deployment plans and their core values, together with a clear rationale for accepting those gaps.
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Organisations should identify and evaluate risks to individuals and groups that may result from their use of AI, including risks that only appear when the system is widely adopted.
Operations Management 2 controls
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Organisations should ensure that datasets used for building models are of high quality and representative, as this is critical to reducing the risk of discriminatory outcomes.
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Organisations should involve relevant internal teams in collaborating on data accountability practices as part of the AI model development and deployment process.
Stakeholder Interaction and Communication 4 controls
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Organisations should provide general information to stakeholders on whether and how AI is used in their products and services, including what AI is, its benefits, and the role AI plays in decision-making.
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Organisations should disclose to individuals how an AI decision may affect them and whether the decision is reversible.
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Organisations should develop and maintain a written policy specifying what explanations to provide to individuals about AI-augmented decisions and when to provide them, ensuring consistency in communication and clarity of roles and responsibilities.
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Organisations should test, evaluate and review their stakeholder communication and relationship strategies for effectiveness on an ongoing basis.
Change history
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