Change control over language model tools

HITRUST CSF requirement statement [?] (06.10hAISecSystem.5)

Changes to language model tools such as agents and plugins are consistently
(1) documented, 
(2) tested, and 
(3) approved 
in accordance with the organization’s software change control policy prior to deployment.

Evaluative elements in this requirement statement [?]

1. Changes to language model tools such as agents and plugins are consistently 
documented in accordance with the organization’s software change control policy prior 
to deployment.

2. Changes to language model tools such as agents and plugins are consistently 
tested in accordance with the organization’s software change control policy prior to 
deployment.

3. Changes to language model tools such as agents and plugins are consistently 
approved in accordance with the organization’s software change control policy prior 
to deployment.

Illustrative procedures for use during assessments [?]

• Policy: Examine policies related to each evaluative element within the requirement statement. Validate the existence of a written or undocumented policy as defined in the HITRUST scoring rubric.
  
  
• Procedure: Examine evidence that written or undocumented procedures exist as defined in the HITRUST scoring rubric. Determine if the procedures and address the operational aspects of how to perform each evaluative element within the requirement statement.
  
  
• Implemented: Examine evidence that all evaluative elements within the requirement statement have been implemented as defined in the HITRUST scoring rubric, using a sample-based test where possible for each evaluative element. Example test(s):
  • For example, select a sample of the language model change documentation to confirm all changes were documented. Further, confirm that the change documentation includes testing and approval information in accordance with the organization’s software change control policy, prior to deployment.
    
    
• Measured: Examine measurements that formally evaluate and communicate the operation and/or performance of each evaluative element within the requirement statement. Determine the percentage of evaluative elements addressed by the organization’s operational and/or independent measure(s) or metric(s) as defined in the HITRUST scoring rubric. Determine if the measurements include independent and/or operational measure(s) or metric(s) as defined in the HITRUST scoring rubric. Example test(s):
  • For example, measures indicate percentage of the organization’s language model that received changes without documentation. Reviews, tests, or audits are completed by the organization to measure the effectiveness of the implemented controls and to confirm that all changes to language model tools such as agents and plugins are consistently documented, tested, and approved in accordance with the organization’s software change control policy prior to deployment.
    
    
• Managed: Examine evidence that a written or undocumented risk treatment process exists, as defined in the HITRUST scoring rubric. Determine the frequency that the risk treatment process was applied to issues identified for each evaluative element within the requirement statement.
  
  

Placement of this requirement in the HITRUST CSF [?]

• Assessment domain: 06 Configuration Management
• Control category: 10.0 – Information Systems Acquisition, Development, and Maintenance
• Control reference: 10h- Control of Operational Software
  
  

Specific to which parts of the overall AI system? [?]

AI application layer:

• AI plugins and agents
  
  

Discussed in which authoritative AI security sources? [?]

• ISO/IEC 42001:2023 Information technology — Artificial intelligence — Management system
  2023, © International Standards Organization (ISO)/International Electrotechnical Commission (IEC)
  • Where:
    • 8. Operation > Operational planning and control > Paragraph 5
    • Annex A > A.6. AI system life cycle > A.6.2.2. AI system requirements and specification
    • Annex A > A.6. AI system life cycle > A.6.2.3. Documentation of AI system design and development
    • Annex A > A.6. AI system life cycle > A.6.2.4. AI system verification and validation
    • Annex A > A.6. AI system life cycle > A.6.2.5. AI system deployment
      
      

• OWASP AI Exchange
  2024, © The OWASP Foundation
  • Where:
    • #DEVPROGRAM
      
      

• Guidelines for Secure AI System Development
  Nov. 2023, Cybersecurity & Infrastructure Security Agency (CISA)
  • Where:
    • 4. Secure operation and maintenance > Follow a secure by design approach to updates
      
      

• Deploying AI Systems Securely: Best Practices for Deploying Secure and Resilient AI Systems
  Apr 2024, National Security Agency (NSA)
  • Where:
    • Continuously protect the AI system > Validate the AI system before and during use > Bullet 3
    • Continuously protect the AI system > Validate the AI system before and during use > Bullet 4
    • Secure AI operation and maintenance > Update and patch regularly > Bullet 1
      
      

• Securing Machine Learning Algorithms
  2021, © European Union Agency for Cybersecurity (ENISA)
  • Where:
    • 4.1- Security Controls > Organizational > Apply documentation requirements to AI projects_
      
      

Control functions against which AI security threats? [?]

• Control function: Preventative
  • Excessive agency
    

Additional information

• Q: When will this requirement included in an assessment? [?]
  • This requirement is only included when the assessment’s in-scope AI system leverages a generative AI model.
  • The Security for AI systems regulatory factor must also be present in the assessment.
    
    

• Q: When is this requirement applicable, and when could it be inapplicable?
  • This requirement is only applicable when language model tools such as agents or plugins are used.
    
    

• Q: Will this requirement be externally inheritable? [?] [?]
  • No. Implementing and/or configuring this requirement is the AI application provider’s sole responsibility.