They bought a platform, implemented a framework, and then discovered that without a clear sense of what they were trying to accomplish, the tools weren't helping. They were generating reports nobody read, tracking metrics nobody acted on, and creating a paper trail that satisfied auditors but didn't reduce risk.
Don't make that mistake with AI.
Strategy is the guiding star, the statement of intent that orients every subsequent decision. Without it, GRC programs become reactive: chasing the latest threat, responding to the latest regulation, fighting whatever fire is burning today. With a clear strategy, the same teams can make deliberate choices about where to invest, what to prioritize, and how to measure success.
What does a good strategy look like? The CISA Cybersecurity Strategic Plan provides a helpful model. It includes three goals: Address Immediate Threats, Harden the Terrain, Drive Security at Scale, each with specific objectives and measurable results. More importantly, it features a "North Star" statement: a single, clear expression of mission that guides all decisions.
For an AI GRC program, the North Star might be something like: "Ensure our organization can leverage AI responsibly, with risks managed to within acceptable tolerance across all operations." Not elegant, but functional. It tells every member of the team what they're working toward.
From there, the six-step process for building a GRC program for AI becomes actionable:
Step 1: Strategy and Planning. Align the AI GRC program with existing organizational strategy and business objectives. Assemble a cross-functional steering committee with representation from IT, cybersecurity, compliance, legal, privacy, HR, and the business units that use or plan to use AI.
Step 2: Inventory. You can't manage what you haven't cataloged. Build an inventory of all AI systems in use, including those from vendors, and establish a process for keeping it current. This is also how you combat Shadow AI.
Step 3: Risk Management Framework. Choose a framework. NIST AI RMF, ISO 42001, the EU AI Act, or another appropriate option based on your industry and geography. The key is to pick one and commit to it.
Step 4: Program, Policy, and Procedures. Translate the framework into internal policies and procedures that reflect your organization's specific context, risk appetite, and regulatory obligations.
Step 5: Implementation. Put the controls in place. This is where governance becomes operational.
Step 6: Monitoring and Improvement. GRC is not a project with an end date. It's an ongoing discipline. Build monitoring into the program, establish review cycles, and create mechanisms for continuous improvement.
Strategy first. Tools second. That's the order that leads to a program that actually works.
From Third Party Threat Hunting™ (TPTH™)
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