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DOD-004-FIRMA-DEMONSTRATIVA-21d7101a · verifică

Prohibited AI Practices Policy

Document ID: DOD-004-001

Module: 04 – Prohibited Practices

Version: 1.0

Status: Approved

Classification: Compliance Core Document

Owner: Compliance Officer

Approval Authority: Management Board

Effective Date: [YYYY-MM-DD]

Next Review Date: [YYYY-MM-DD]

1. PURPOSE

This policy defines the organization's mandatory rules for preventing the development, deployment, procurement, or use of Artificial Intelligence systems that fall under prohibited practices as defined by Regulation (EU) 2024/1689 (EU AI Act).

The objective is to ensure that no prohibited AI system is intentionally or unintentionally introduced into organizational operations.

2. SCOPE

This policy applies to:

All employees and contractors
All business units and subsidiaries
All third-party vendors and service providers
All AI systems, tools, and services used directly or indirectly
All data processing workflows involving AI systems

3. REGULATORY BASIS

This policy is based on Article 5 of Regulation (EU) 2024/1689 (EU AI Act), which defines prohibited AI practices.

4. POLICY STATEMENT

The organization SHALL NOT:

Develop prohibited AI systems
Deploy prohibited AI systems
Integrate prohibited AI systems into internal workflows
Procure prohibited AI systems from third parties
Intentionally facilitate prohibited AI use

Any suspected prohibited AI usage MUST be immediately escalated for compliance review.

5. PROHIBITED PRACTICES (CONTROLLED LIST)

The following categories are considered prohibited under applicable regulation:

Manipulative or deceptive AI systems causing significant harm
Exploitation of vulnerabilities of specific groups
Social scoring systems in prohibited contexts
Real-time remote biometric identification in restricted public spaces (subject to legal exceptions)
Any AI system explicitly defined as prohibited under Article 5 updates

6. CONTROL REQUIREMENTS

The organization SHALL implement:

Pre-deployment AI assessment
Vendor due diligence for AI tools
AI system inventory maintenance
Periodic compliance review
Incident reporting mechanism

7. RESPONSIBILITIES

7.1 Management

Ensure enforcement of this policy
Provide necessary resources
Approve exceptions (if legally permitted)

7.2 Compliance Officer

Maintain prohibited AI register
Conduct periodic audits
Validate AI system classification
Maintain evidence records

7.3 AI System Owners

Declare AI usage
Provide system documentation
Cooperate with compliance assessments

8. PROHIBITED AI ASSESSMENT PROCESS

Before any AI system is used, the following MUST be performed:

1. Identify AI system functionality

2. Map against prohibited categories

3. Evaluate intended use case

4. Assess downstream risk

5. Document findings in compliance register

6. Approve or reject usage

9. EXCEPTION POLICY

No exception shall permit the use of an explicitly prohibited AI practice.

Where legal interpretation is uncertain, the system SHALL be escalated to compliance/legal review prior to deployment.

10. EVIDENCE REQUIREMENTS

The following records MUST be maintained:

AI system inventory entries
Prohibited practices checklist
Risk assessment documentation
Compliance declaration
Vendor documentation (if applicable)
Audit logs

11. MONITORING & REVIEW

This policy shall be:

Reviewed annually
Updated upon regulatory changes
Audited during internal compliance cycles

12. NON-COMPLIANCE

Failure to comply with this policy may result in:

Suspension of AI system usage
Disciplinary action
Contract termination (for vendors)
Regulatory reporting where applicable

13. APPROVAL

Approved by:

Compliance Governance Authority

Date: [YYYY-MM-DD]