In v11.4.0 of the HITRUST CSF (to be released Nov. 2024) and later, a new AI Cybersecurity regulatory factor will be made available. This factor can be optionally added to HITRUST e1, i1, and r2 readiness and validated assessments which include within the scope of the assessment an IT platform that leverages an AI model.

When the AI Cybersecurity compliance factor is added to a HITRUST assessment, three additional tailoring questions will be asked:

The following table includes information about each potential response to question 1. These will be presented as checkboxes in MyCSF (not as radio buttons), allowing many to be selected for a single assessment (as is needed if the assessment’s in-scope IT platforms leverage more than one type of AI model).

Factor / response Description Examples and behavior considerations Impact on the assessment
Rule-based AI model (aka “heuristic models”, “traditional AI, “expert systems”, “symbolic AI” or “classical AI”) Rule-based systems rely on expert software written using rules. These systems employ human expertise in solving complex problems by reasoning with knowledge. Instead of procedural code, knowledge is expressed using If-Then/Else rules. HITRUST AIE, AML systems for financial institutions, prescription dosing calculators Adds 28 “base AI security” HITRUST CSF requirement statements
Predictive AI model (i.e., a non-generative machine learning model) These are traditional, structured data machine learning models used to make inferences such as predictions or classifications, typically trained on an organization’s enterprise tabular data. These models extract insights from historical data to make accurate predictions about the most likely upcoming event, result or trend. In this context, a prediction is does not necessarily refer to predicting something in the future. Predictions can refer to various kinds of data analysis or production applied to new data or historical data (including translating text, creating synthetic images or diagnosing a previous power failure). scikit-learn, XGBoost, PyTorch and Hugging Face transformer models Adds 28 “base AI security” requirements
+ 7 additional requirements
(2 of which are non-GenAI only)
= 35 added requirements
Generative AI model (through a foundation model) Generative AI (gen AI) is artificial intelligence that responds to a user’s prompt or request with generated original content, such as audio, images, software code, text or video. Most generative AI models start with a foundation model, a type of deep learning model that “learns” to generate statistically probable outputs when prompted. Large language models (LLMs) and small language models (SLMs) are common foundation models for text generation, but other foundation models exist for different types of content generation. OpenAI ChatGPT, Anthropic Claude, Meta LLAMA, Google Gemma, Amazon Titan, Microsoft Phi Adds 28 “base AI security” requirements
+ 9 additional requirements
(4 of which are genAI only)
= 37 added requirements

The following table describes question 2 and 3. These will be presented as radio buttons in MyCSF, allowing only one answer. If the assessment’s in-scope IT platforms leverage many models, assessed entities should use a high-water mark approach to answering these two questions. For example, if one in-scope model is open source and the other model is closed source and confidential to the organization, question 3 should be answered affirmatively.

Question no. Question Description Impact on the assessment
2 Was confidential and/or covered data used to train the model, tune the model, or enhance the model’s prompts via RAG? AI models often require large volumes of data to train and tune. This data, as well as the sources of organizational data used for prompt enhancement through retrieval augmented generation (RAG), is very often confidential and/or covered information. When this is true, additional protections must be in place to prevent the theft and leakage of this data through the AI system.

Per the per the HITRUST Glossary:
  • Covered information is “any type of information (including data) subject to security, privacy, and/or risk regulations that is to be secured from unauthorized access, use, disclosure, disruption, modification, or destruction to maintain confidentiality, integrity, and/or availability.
  • Confidential information is as any type of information (including data) that is not to be disclosed to unauthorized persons, processes, or devices.
Adds 4 requirements if true, which deal with protections (e.g., encryption, access control, added model robustness) over the training, tuning, and augmentation data.
3 Are the model’s architecture and parameters confidential to the organization? The training of an AI model can be a significant undertaking. While some AI models are open source, the inner workings of many AI models and the models themselves represent valuable intellectual property for the organization that created them. When this is true, additional protections must be in place to prevent the theft of the model and leakage of model parameters. Adds 4 requirements if true, all of which map to the model extraction and theft and model inversion threats.

MyCSF uses the collective responses to these questions to appropriately tailor the HITRUST CSF assessment to the specifics of the organization’s AI deployment context. The following table shows the different requirement statement counts possible based on different combinations of responses to these tailoring questions. Note that this table contemplates only a single model type included in the scope of the assessment. As stated above, more than one IT platform can be included in the scope of a HITRUST CSF assessment which leverages an AI model. When this is true, the assessed entity should select all model types that apply for question 1 and should follow a high-water mark approach to answering questions 2 and 3.

Q2: Sensitive data used Q3: Confidential model used? Requirement count
Rule-based AI model
No No 28
Yes No 30
No Yes 31
Yes Yes 31
Non-generative ML model
No No 35
Yes No 39
No Yes 39
Yes 40
Generative AI model
No No 37
Yes No 40
No Yes 40
Yes Yes 40

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Jeremy Huval wrote: Sep 13, 2024

Great recommendation. Done!


Walter Haydock (StackAware) wrote: Sep 12, 2024

I recommend clarifying what “sensitive and/or confidential data” means. Training data might be publicly available but still subject to regulatory requirements like the European Union (EU) General Data Protection Regulation (GDPR) and thus be “sensitive.”