6/4/2025 AI Data
Governance
Checklist
“An Implementation Guide”
Morgan signing House 2025
1 “AI Data Governance check list – A support to AI Implemenattion check List and Guide”
Table of Contents
1. Introduction
2. Section 1: Data Availability & Quality
3. Section 2: Data Classification & Security
4. Section 3: Ethical AI & Compliance
5. Section 4: Data Stewardship & Lineage
6. Section 5: Continuous Data Governance
7. Instructions for Questionnaire Deployment
8. References
2 “AI Data Governance check list – A support to AI Implemenattion check List and Guide”
AI Data Governance Checklist & Implementation Guide
Inspired by "AI Assessment & Implementation Guide" (MSH 2025) and enriched with insights
from global AI governance sources including ISO/IEC 42001, EU AI Act alignment, CAISO model,
and data governance frameworks for generative and agentic AI.
Introduction
In AI governance, poor data quality isn’t just a technical issue, it’s a business risk. Inaccurate,
incomplete, or biased data can distort model predictions, erode trust, and introduce
regulatory exposure. This document provides a structured AI data governance framework
with a focus on ensuring high-quality data and includes an actionable checklist and
deployment guide.
Section 1: Strategic Data Alignment
1.1 Mission Alignment
• Are AI data initiatives aligned with the organization’s digital transformation goals?
• Have data dependences for strategic AI use cases been identified?
• Does real data exist?
• Does data collection mechanism exist in the organization?
1.2 Business Impact Mapping
• Have data-driven AI use cases been prioritized by ROI, compliance risk, or customer
value?
Section 2: AI Data Leadership & Oversight
2.1 Executive Sponsorship
• Is there a CAIO/CDO/CAISO accountable for data and AI governance?
3 “AI Data Governance check list – A support to AI Implemenattion check List and Guide”
2.2 Governance Forums
• Is a cross-functional Data & AI Governance Council in place (including Legal, Risk, IT,
Ethics) to support program?
• Are policies ratified at Board or Subcommittee level?
Section 3: Data Architecture & Infrastructure
Readiness
3.1 Data Ecosystem Audit
• Are all AI-relevant datasets cataloged with metadata, sensitivity, and ownership tags?
• Are data platforms aligned with FAIR principles (Findable, Accessible, Interoperable,
Reusable)?
3.2 Lineage & Observability
• Are lineage tracking tools implemented (e.g., Apache Atlas, Collibra, Talend)?
• Are end-to-end lineage maps used to validate model inputs?
Section 4: AI Data Quality Governance Framework
4.1 Why Data Quality Matters
• Impacts model accuracy, fairness, and explainability.
• Influences compliance with global standards and legislation.
• Supports auditability and operational scaling.
• Enables scalable, auditable AI systems
4.2 Key Dimensions of AI Data Quality
Dimension Description Example Checklist Item
Data reflects real-world
Accuracy ☑ Are invalid or placeholder values filtered out?
conditions
No missing fields or critical
Completeness ☑ Are datasets ≥ 95% complete before training?
gaps
Standardized schemas and
Consistency ☑ Are all fields normalized across platforms?
units
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Data freshness and refresh ☑ Are update intervals aligned with model
Timeliness
cadence expectations?
Removal of duplicates and ☑ Are deduplication protocols embedded in
Uniqueness
artifacts pipelines?
Relevance Fit-for-purpose data curation ☑ Is outdated or non-essential data pruned?
4.3 Data Profiling & Readiness Checks
• ☑ Are data profiling tools (e.g., Great Expectations) used routinely?
• ☑ Are validation rules and thresholds defined for key datasets?
• ☑ Is a retry/remediation process in place when quality drops?
4.4 Dark Data & Non-Structured Sources
• ☑ Are unstructured files mapped, OCR-processed, and classified?
• ☑ Is metadata attached for discoverability and governance?
4.5 Quality Monitoring & Metrics
Metric Purpose
% Completeness Ensure no field dropout
Data Drift Score Flag distributional shifts
Timeliness Index Assess data freshness
Validation Pass Rate Track rule-based data fitness
4.6 Tools & Dashboards
Tool Function
Monte Carlo Data observability
Talend ETL pipeline & transformation
Collibra Governance & stewardship
SHAP/LIME Model transparency via data
Section 5: Data Security & Classification for AI
5.1 Access Controls
• Is RBAC or ABAC enforced on all data sources for AI use?
• Are regular access reviews and entitlement audits conducted?
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5.2 Sensitive Data Handling
• Is PII/PHI masked, tokenized, or anonymized prior to model training?
• Is end-to-end encryption (TLS1.2+, AES-256) in place for data in transit and at rest?
Section 6: Ethical Data Use & Compliance Alignment
6.1 Ethics Board Review
• Are high-risk AI use cases data subject to formal Ethics Board review?
• Are bias data audits conducted pre- and post-deployment?
6.2 Compliance Mapping
• Is each AI model mapped to applicable standards (e.g., ISO/IEC 42001, ISO/IEC 27001,
GDPR, CCPA, EU AI Act)?
• Are automated checks in place for regulatory policy triggers to check data?
Section 7: Stewardship, Ownership & Lineage
Governance
7.1 Defined Roles
• Are data owners and stewards assigned to each dataset and model?
• Are responsibilities tracked in a RACI matrix?
7.2 Auditability
• Are immutable logs retained for data access, transformation, and model output events?
Section 8: Data Risk Management
8.1 Risk Register
• Is there a centralized register tracking data quality, privacy, lineage, and security risks?
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• Are data-related risks scored, and mitigation plans documented?
8.2 Incident Readiness
• Are data-related AI breaches covered in the organization’s IR playbook?
Section 9: Model Transparency & Data Traceability
9.1 Explainability Assets
• Are Data Sheets and Model Cards available for every production model?
9.2 Traceback Protocols
• Can each model output be traced back to the data source, transformation, and version?
Section 10: Continuous Data Governance Improvement
10.1 Lifecycle Monitoring
• Are metrics and logs continuously monitored for drift, degradation, and risk?
• Are retraining triggers based on data quality thresholds?
10.2 Policy Refresh Cadence
• Are data governance policies reviewed at least every 6 months?
• Are updates communicated via dashboards and stakeholder briefings?
Appendix: Maturity Markers for AI Data Governance
• Level 1: Ad Hoc – No clear ownership or governance.
• Level 2: Defined – Basic roles and processes exist.
• Level 3: Operationalized – Cross-functional governance in action.
• Level 4: Measured – KPIs tracked, audits performed.
• Level 5: Adaptive – Continuous improvement, policy agility, regulatory alignment.
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Instructions for Questionnaire Deployment
• Question Types: For each question, determine whether it is:
Yes/No (e.g., “Is there an AI Ethics Board?”),
Multiple Choice (e.g., “Which AI frameworks are considered? [TensorFlow,
PyTorch, Scikit-Learn, Other]),
Rating Scale (e.g., “Rate our data quality: 1 = Poor, 5 = Excellent”), or
Open-Ended (e.g., “Describe the primary AI objectives for your business unit”).
• Question Types: Use Yes/No, Multiple Choice, Rating Scale, or Open-Ended formats.
• Survey Logic: Use skip logic (e.g., if 'No' to CAISO, skip to alternate responsibility).
• Required vs. Optional: Mark sections like Data Security and Risk Governance as 'Required'.
• Sections & Progress Bar: Organize by topic and display progress to respondents.
• Distribution: Send to all relevant stakeholders (e.g., IT, compliance, exec sponsors).
• Living Document: Revise based on responses and feedback to fill governance gaps.
Use this questionnaire as a living document: iterate after initial responses, refine questions to
address gaps, and ensure every area—Strategy, Leadership & Governance, Technology, Data
Governance, Security & Risk, Talent & Change, Pilot & MLOps, KPI Monitoring, and Board
Oversight—is thoroughly covered before embarking on or scaling AI initiatives.
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References
- Morgan Signing House (2025). AI Assessment & Implementation Guide.
- Pullum, S. (2025). CONVERGENCE. The CAISO. Copenhagen Compliance.
- Agrawal, A., Gans, J., & Goldfarb, A. (2018). Prediction Machines.
- Advisera. How to Handle Artificial Intelligence Threats Using ISO 27001.
- Patrick Sullivan. Bridging the Gaps – ISO/IEC 42001 and EU AI QMS.
- Risk3Sixty. Step-by-Step Guide to ISO 42001 Certification.
- SSRN. Risks and Limitations of Generative AI Systems. SSRN ID: 5191295
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