ISO 27001 and AI Governance

Understanding Generative AI in an ISO 27001 Context

ISO/IEC 27001 is an international standard for establishing, implementing, maintaining, and continually improving an Information Security Management System (ISMS).

The use of generative AI systems introduces new ways that information may be accessed, processed, shared, and stored. Depending on how these systems are deployed and used, organizations may need to evaluate whether existing information security controls remain appropriate.

From an ISO 27001 perspective, the primary question is not whether AI can be used. The question is whether AI introduces new information security risks that should be identified, assessed, and managed within the organization's ISMS.

This matters because:

• employees may share sensitive information with AI systems
• AI services may introduce new vendors, processing activities, or information flows
• organizations remain responsible for managing information security risks associated with the technologies they use

What ISO 27001 Covers

ISO/IEC 27001 is an international standard that provides requirements for an Information Security Management System (ISMS).

The standard helps organizations manage information security risks through a structured and risk-based approach.

ISO 27001 focuses on protecting information through controls designed to support:

• confidentiality
• integrity
• availability

Organizations use ISO 27001 to establish governance processes that identify risks, evaluate their impact, and determine appropriate controls.

Key Terms (Simplified)

Information Security Management System (ISMS)

A structured framework used to manage information security risks and controls across an organization.

Information Assets

Information and related resources that have value to an organization.

Examples may include:

• customer data
• employee records
• source code
• contracts
• financial information
• intellectual property

Information Security Risk

The potential for threats, vulnerabilities, or events to affect the confidentiality, integrity, or availability of information.

Risk Assessment

The process of identifying, analyzing, and evaluating information security risks.

Risk Treatment

The process of selecting and implementing measures to address identified risks.

Controls

Administrative, technical, physical, or organizational measures used to reduce risk.

Responsibilities of Organizations

Organizations operating an ISO 27001 ISMS are generally responsible for:

• identifying information security risks
• assessing the impact of those risks
• implementing appropriate controls
• monitoring the effectiveness of controls
• continually improving information security processes

These responsibilities continue to apply when AI systems are introduced into business workflows.

How Generative AI Changes Information Security Risk

Generative AI systems may introduce new information security risks by creating additional ways that information can be accessed, processed, or shared.

Examples include:

• unauthorized disclosure of information
• uncontrolled sharing of sensitive data
• use of unapproved AI tools
• expanded third-party dependencies
• increased access to information assets

These risks do not necessarily make AI inappropriate to use. However, they may require additional evaluation and controls within the ISMS.

Where AI Interacts with ISO 27001 Controls

Information Classification

Organizations may need to determine what types of information can be shared with AI systems and under what circumstances.

Access Control

AI systems may create new pathways through which users interact with information assets.

Supplier and Third-Party Risk

The use of external AI providers may introduce additional supplier-related security considerations.

Monitoring and Oversight

Organizations may require visibility into how AI systems are being used and what information is being processed.

Data Protection

Organizations may implement controls designed to reduce the risk of unauthorized disclosure of sensitive information.

What Teams Actually Do (and Where Risk Starts)

In practice, employees often use AI systems to improve productivity.

Examples include:

• customer support teams summarizing customer communications
• developers reviewing source code
• HR teams analyzing resumes
• finance teams summarizing reports
• legal teams reviewing documents

These activities are often legitimate business uses of AI.

The challenge is that they may occur:

• outside approved processes
• without visibility into information flows
• without consistent information classification
• without formal risk assessment
• without security review

As a result, organizations may not fully understand how information assets are being shared or processed.

Risk Assessment and Generative AI

Risk assessment is a central concept within ISO 27001.

When organizations introduce AI systems, they may evaluate questions such as:

• What information assets are involved?
• Could sensitive information be disclosed?
• Are additional third-party risks introduced?
• Do existing controls remain effective?
• Are new controls necessary?

The answers help determine whether risk treatment measures should be implemented.

Why AI Usage Becomes Difficult to Govern

Individually, AI-related activities may appear manageable.

In combination, organizations may face situations where:

• information moves across multiple systems
• AI usage occurs outside approved workflows
• third-party processing increases
• security controls are applied inconsistently
• visibility into information handling becomes limited

These challenges can make it more difficult to manage information security risks consistently.

The Core Problem: AI Introduces New Information Security Risks

Generative AI often creates new pathways through which information assets can be accessed, shared, or processed.

Without appropriate governance, organizations may struggle to:

• understand how information is being used
• apply controls consistently
• monitor AI-related activities
• demonstrate that risks are being managed appropriately

From an ISO 27001 perspective, the issue is not the existence of AI itself. The issue is whether AI-related risks are identified, assessed, treated, and monitored through the organization's ISMS.

How AI Governance Supports ISO 27001 Objectives

Organizations may implement AI governance controls to help manage information security risks.

Examples include:

• identifying sensitive information before submission
• enforcing AI usage policies
• maintaining visibility into AI interactions
• restricting certain categories of information
• supporting monitoring and risk management processes

These controls may support an organization's information security objectives and broader risk-management efforts.

Where Wald.ai Fits

Wald provides controls that organizations may use to manage AI-related information security risks.

This includes:

• detection of sensitive information
• redaction before information is sent to AI systems
• policy enforcement across users and teams
• visibility into AI interactions
• support for enterprise DLP and AI governance programs

These capabilities can help organizations implement controls that support information security objectives while enabling productive use of AI technologies.

FAQs

Is generative AI compliant with ISO 27001?

ISO 27001 does not prohibit the use of generative AI. Organizations remain responsible for identifying, assessing, and managing information security risks associated with AI systems within their ISMS.

Does ISO 27001 require AI governance?

ISO 27001 does not specifically require AI governance. However, organizations may evaluate AI-related risks as part of their broader information security risk-management processes.

Can confidential information be entered into AI systems?

Organizations should evaluate whether the use of AI is appropriate for the information involved and whether sufficient controls exist to protect confidentiality, integrity, and availability.

What is an Information Security Management System (ISMS)?

An ISMS is a structured framework used to manage information security risks and controls across an organization.

Why is AI governance important for ISO 27001?

AI governance can help organizations maintain visibility into AI usage, manage information security risks, and support consistent application of security controls.

‍