Purpose
Produce a defensible, governance-ready risk assessment of a specific AI system in its specific deployment context — surfacing inherent risk across seven dimensions, prescribing concrete mitigations, and reporting residual risk so decision-makers can approve, condition, or reject adoption with full visibility.
When to Use
Invoke this skill when the user asks to:
- Assess the risk of adopting a new AI tool, vendor, or model
- Conduct an AI governance review for a system already in use
- Create an AI risk register entry for an internal system or feature
- Run a pre-launch risk review for an AI-powered product or workflow
- Evaluate a third-party AI vendor as part of due diligence
- Determine whether an AI use case is high-risk under EU AI Act, NIST AI RMF, or internal policy
Inputs Required
Before starting, collect:
- System description: What the AI does — model type (LLM, classifier, generative, agentic), provider, key capabilities
- Deployment context: Where it operates — internal tool, customer-facing, embedded in product, autonomous agent
- Use case and decisions: What decisions or outputs the AI drives, and what humans do with them
- Data inputs: What data flows in — PII, PHI, financial, proprietary, public, customer content
- User population: Who interacts with it — employees, customers, regulated populations (minors, healthcare patients, applicants)
- Jurisdictions: Where users and data live — relevant for GDPR, EU AI Act, CCPA, HIPAA, sector regulations
- Existing controls: What governance, monitoring, or guardrails are already in place
If jurisdictions or existing controls are unspecified, assume US + EU exposure and no controls in place, and note the assumption explicitly.
Instructions
Step 1: Classify the System and Set Inherent Risk Baseline
Before assessing dimensions, establish the risk envelope:
- Autonomy level: Advisory (human decides) / Augmented (human reviews) / Automated (human can override) / Autonomous (no human in loop) — higher autonomy raises baseline risk by one tier
- Impact level: Low (informational), Medium (operational efficiency), High (affects customers/employees materially), Critical (affects safety, rights, finances, or legal status)
- Regulatory classification: Determine EU AI Act tier (Minimal / Limited / High-Risk / Prohibited), whether HIPAA/GLBA/FCRA/EEOC applies, and any sector-specific regimes
- Baseline tier: Combine autonomy + impact + regulatory classification into an initial inherent risk tier (Low / Medium / High / Critical)
State the baseline tier explicitly before proceeding.
Step 2: Assess Across Seven Risk Dimensions
For each dimension, produce: (a) specific findings tied to this system, (b) inherent risk rating (Low/Medium/High/Critical), (c) prescribed mitigations, (d) residual risk rating after mitigations applied.
Dimension 1 — Model Risk What can go wrong with the model itself:
- Hallucination and factual error rates in the use case
- Prompt injection, jailbreaks, adversarial inputs
- Model drift, version changes by vendor, deprecation risk
- Lack of explainability for consequential decisions
- Overreliance — users trusting outputs without verification
- Performance degradation on edge cases or underrepresented populations
Dimension 2 — Data Risk What can go wrong with data flowing in or out:
- Sensitive data (PII, PHI, financial, IP, trade secrets) sent to third-party models
- Training data exposure — does the vendor train on inputs?
- Data residency violations (e.g., EU data sent to US-hosted model)
- Output data classification — is generated content treated as a new record?
- Retention, deletion, and right-to-erasure handling
- Data poisoning risk for retrievable/fine-tuned systems
Dimension 3 — Security Risk Attack surface and infrastructure exposure:
- Authentication, authorization, and access controls on the AI surface
- API key and credential handling
- Output handling — can model outputs trigger downstream code execution, queries, or actions (especially in agentic systems)?
- Tool/plugin/MCP server access scope — what can the AI actually do?
- Logging, audit trail completeness, tamper resistance
- Vendor security posture — SOC 2, ISO 27001, penetration testing cadence
Dimension 4 — Operational Risk What breaks the business if this fails:
- Vendor concentration and lock-in
- Availability, SLA, and fallback when the AI is down
- Cost volatility — token costs scaling unpredictably
- Latency and throughput under load
- Change management — vendor model updates breaking workflows
- Skill dependency — does only one team know how to operate or fix this?
Dimension 5 — Legal, Regulatory & Compliance Risk Where regulators or courts can intervene:
- EU AI Act obligations for the system's tier (transparency, conformity assessment, human oversight, technical documentation)
- GDPR / CCPA — automated decision-making rights, DPIA requirements, lawful basis
- Sector regimes: HIPAA (healthcare), FCRA/ECOA (credit and hiring), SEC/FINRA (financial advice), FTC (deceptive practices)
- IP exposure — copyright in training data, output ownership, indemnification from vendor
- Contractual obligations — customer DPAs, confidentiality terms, AI disclosure clauses
- Cross-border transfer mechanisms (SCCs, adequacy decisions)
Dimension 6 — Ethical & Bias Risk Where outcomes can be unfair or harmful:
- Disparate impact across protected classes in any decisioning use case
- Representation gaps in training data affecting underrepresented users
- Dignity and harm risks — content that demeans, misgenders, or stereotypes
- Manipulation risk — does the system nudge users in ways they wouldn't consent to?
- Affected populations who can't opt out (employees subject to AI monitoring, applicants screened by AI)
- Bias testing methodology and documented evaluation results
Dimension 7 — Reputational Risk What public failure looks like:
- Headline risk — is the use case the kind that makes news if it fails (children, healthcare, hiring, content moderation, surveillance)?
- Stakeholder reactions — employees, customers, investors, regulators, press
- Incident disclosure obligations — when does this need to be reported?
- Social media amplification potential of a single bad output
- Trust erosion — repeat-failure visibility
Step 3: Risk Heat Map
Produce a summary table:
| Dimension | Inherent Risk | Mitigations Applied | Residual Risk |
|---|---|---|---|
| Model | |||
| Data | |||
| Security | |||
| Operational | |||
| Legal/Regulatory | |||
| Ethical/Bias | |||
| Reputational |
Step 4: Mitigation Plan
Consolidate prescribed mitigations across all dimensions into a single action list, organized by:
- Pre-deployment blockers — must be in place before go-live
- Conditional controls — required within 30/60/90 days
- Ongoing controls — continuous monitoring, review cadence
- Owner: Function responsible (Legal, Security, Data, ML/Product, Compliance)
Step 5: Overall Residual Risk and Recommendation
Provide a final governance recommendation:
- Recommendation: Approve / Approve with conditions / Defer pending controls / Reject
- Overall residual risk tier: Low / Medium / High / Critical
- Conditions or blockers: Specific items that must be true for approval
- Re-review trigger: What changes would require reassessment (new use case, vendor model change, jurisdiction expansion, incident)
- Re-review cadence: When this assessment expires (typically 6 or 12 months)
Be opinionated. Do not hedge the recommendation.
Output Format
- Structure: System classification → Seven dimension assessments → Risk heat map table → Mitigation plan → Final recommendation
- Length: 1,500–2,200 words
- Format: Structured document with headers, dimension subsections, a heat map table, and a numbered mitigation action list
- Sections: System Classification & Baseline; Seven Risk Dimensions (each with findings, inherent rating, mitigations, residual rating); Risk Heat Map; Mitigation Plan; Recommendation & Re-Review Triggers
- Tone: Director of AI governance — measured, specific, decision-oriented; cites concrete regulatory regimes by name; avoids both hype and FUD
Quality Checklist
Before delivering output, verify:
- [ ] All seven risk dimensions are assessed — none skipped or merged
- [ ] Each dimension has both an inherent rating AND a residual rating after mitigations
- [ ] Regulatory references are specific (EU AI Act article tier, HIPAA, FCRA, etc.) — not generic "regulations apply"
- [ ] Mitigations are concrete actions with owners — not vague guidance like "improve monitoring"
- [ ] The heat map table is present and complete across all seven dimensions
- [ ] Final recommendation is one of the four explicit options — no hedging
- [ ] Re-review trigger and cadence are stated
Notes
- The most common assessment failure is rating everything "Medium" — push for differentiation across dimensions; some risks genuinely are Low, others genuinely Critical
- Agentic systems (those that take actions via tools) should almost always be rated higher on Security and Operational dimensions than chat-only systems with similar use cases
- If the system processes data subject to GDPR Article 22 (automated decisions with legal effect), this is a near-automatic High-Risk classification under the EU AI Act — flag it loudly
- Vendor-provided AI assessments and SOC 2 reports are inputs, not substitutes for this assessment — the deployment context determines risk, not the vendor's controls alone
- When in doubt between two tiers, choose the higher tier and document the reasoning — governance defensibility favors conservatism
How to use this skill
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