Purchased models, outsourced development, staff using AI on their own: which evidence is still yours?

When you build a third-party model into your own product, outsource AI development, or staff use browser extensions and personal accounts, ISO 42001 responsibility does not disappear with outsourcing; separate the evidence you can request from suppliers, what you must verify yourself, and the limits that remain.

Updated 2026-10-29

Direct answer: buying a model or outsourcing development does not outsource the responsibility. When you integrate a third-party foundation model into your own customer-service product, you remain responsible for your retrieval data, prompt design, tool integration and go-live approval; when development is outsourced, data, acceptance, go-live decisions and incident handling stay with the commissioning company; when staff use browser extensions or personal accounts for company work, that is AI use the organisation must manage. ISO/IEC 42001 asks you to write down responsibilities, evidence and exception handling for all three situations and keep them up to date.

Responsibilities in the three situations

SituationWhat you can require from suppliers or contractorsWhat you must do yourselfLimits that remain
Third-party model in your own productModel version, usage restrictions, overall test results, data processing termsTests of your own data and prompts, go-live approval, user notices, incident handlingWhere the supplier does not disclose training data, only black-box testing and contract terms can compensate
Outsourced developmentDevelopment documents, test reports, version records, delivery listAcceptance criteria, data access, go-live approval, decisions on model updates and incidentsKnowledge gaps when the contractor changes staff or the contract ends
Staff using AI on their own—Allow list, exception requests, re-assessment of new uses, trainingA one-off inventory never finds every use; you need ongoing discovery

What a consultant should deliver

How to accept the work

For any purchased or outsourced AI system, the inventory leads to the owner, contract clauses, acceptance records and the latest re-assessment; when staff propose a new use, there are records of the request, assessment and approval or refusal.

What cannot be guaranteed

A consultant cannot prove what a supplier does not disclose; what can be done is to put requirements into contracts, obtain your own evidence through black-box testing, and have the responsible manager accept the residual risk in writing.

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.

Related questions

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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.

DimensionThe question it answersTypical gap when only this part is done
Process (management system)Who is responsible, what is done, when, where the evidence is, how it improvesTools are in place but nobody runs them on schedule, so there are no records at audit time
Security technologyHow controls are designed and how their effectiveness is verifiedDocuments are complete but the systems do not actually do what they describe
Legal complianceWhich regulation applies, which role you hold, the deadlines and penaltiesControls 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.

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