Direct answer: three post-go-live situations most often defeat the system. First, model drift is hidden by sales staff correcting outputs by hand, official indicators still show targets met, and management review cannot see the real risk. Second, after a wrong AI recommendation, development says it was a usage problem, sales says it was the model and security says there was no intrusion, so nobody investigates. Third, when an old system is retired and the supplier changes, there are no rules on whether prompt logs, customer data, model outputs and approval evidence are kept, transferred or deleted. ISO/IEC 42001 requires procedures for monitoring, incident handling, corrective action and retirement, with the results fed into management review.
Mechanisms for the three situations
| Situation | Mechanism |
|---|---|
| Drift hidden by manual fixes | Monitoring records the number of manual overrides and reasons alongside the indicators; complaints and override rates are part of the thresholds; they trigger retraining or switch-off |
| Teams blaming each other | AI incident triage rules, evidence preservation, root-cause investigation, internal and external communication, correction and effectiveness checks; plus a check on whether statutory notification applies |
| Retirement and supplier change | Data transfer, deletion, retention, access revocation and exit acceptance; retention periods decided per data class by legal basis or contract, not kept forever by default |
What a consultant should deliver
- A post-go-live monitoring plan: indicators, override records, complaints, thresholds and triggered actions
- An AI incident management procedure linked to the existing security incident process
- A retirement and supplier transition procedure with a data classification and retention table
- A list of inputs for management review so the real risk is visible
How to accept the work
For any live system, you can see the latest monitoring results and override statistics; for any AI-related incident, you can see the triage, root cause, correction and effectiveness check; for any retired system, you can see the data disposal and exit acceptance records.
What cannot be guaranteed
The system makes problems visible and assigns them, but does not guarantee they will not recur; whether an event must be notified to authorities depends on the applicable law.
Winners Consulting's approach
The following describes Winners Consulting's own approach. Please test us with the same questions above, and test other consultants too.
- Who leads: VP- and director-level consultants guide the whole engagement, without outsourcing
- Project rhythm (as listed on our service page): scope and inventory 2–4 weeks, risk and impact assessment 3–5 weeks, system build 6–10 weeks, audit and certification 4–8 weeks; organisations that already hold ISO 27001 usually reach certification in 4–6 months, from scratch about 6–9 months
- Division of roles: we build the system and the evidence chain; legal opinions come from partner lawyers; certification is carried out by a certification body accredited under ISO/IEC 42006, which we accompany but do not stand in for
- Completed work (anonymous, under a non-disclosure agreement): an industrial automation manufacturer built an AI system inventory, completed AI risk classification, established algorithm review and human oversight for high-risk uses, and obtained ISO 42001 certification
Related questions
- Should AI incidents be handled separately from security incidents? They can share one incident process, but AI incidents often involve no intrusion and stem from data, model or use; triage rules must recognise them and assign investigation. ISO 42001 implementation
- Must all data be deleted when an AI system is retired? Not necessarily. Decide retention or deletion per data class by legal basis or contract, and keep a disposal record. AI governance consulting
Request a free mechanism diagnosis
Compliance needs all three; a consultant's value is integration
CRA, TISAX, ISO 27701 and the AI Act are not single technical problems. They are only complete when process, security technology and legal compliance all hold at the same time. Fix only one and the gaps in the other two surface during audits, incident reporting or customer due diligence, and the work has to be redone.
| Dimension | The question it answers | Typical gap when only this part is done |
|---|---|---|
| Process (management system) | Who is responsible, what is done, when, where the evidence is, how it improves | Tools are in place but nobody runs them on schedule, so there are no records at audit time |
| Security technology | How controls are designed and how their effectiveness is verified | Documents are complete but the systems do not actually do what they describe |
| Legal compliance | Which regulation applies, which role you hold, the deadlines and penalties | Controls are built against the wrong regulation or role, so obligations are not covered |
Winners' consulting team covers all three dimensions and plans regulatory scoping, process design and technical controls together, so a single body of evidence serves multiple regulations and customer requirements.