The GRC data an organization keeps on itself
The Operating Registers · Companion to the Atlas

The GRC data an organization keeps on itself

The Atlas covered the external laws. This guide covers the six internal records a firm uses to actually govern: its policies, controls, risks, mitigations, audit findings, and compliance mappings — with every real entry from the database explained.

The one idea to hold onto

These six records form a single chain of accountability

The external frameworks tell you what's required. Everything below is how the organization responds — and each record links to the next, so you can trace any single safeguard from the rule that demands it all the way to the proof it works. Read the chain left to right:

01
PoliciesWhat we require of ourselves
02
ControlsThe mechanisms that deliver it
03
RisksWhat we're worried about
04
MitigationsOur dated plan to reduce them
05
Audit findingsIndependent proof it works
06
Compliance mappingsEvidence tied to each rule
1
The register of intent · 12 entries

Policies

The rules the organization writes for itself — each owned by a named executive.

A policy sets a requirement but doesn't enforce it; that's the controls' job. What to read on each: its owner (who's accountable) and its status — only an Active policy has real authority. Watch for the two that aren't active.

P01 · Data Privacy

Data Protection & Privacy

How personal data is collected, processed, and stored.

Chief Privacy OfficerActive
P02 · Security

Information Security

The master framework for protecting information assets.

CISOActive
P03 · Security

Access Control

Who can reach which systems — least privilege.

CISOActive
P04 · Security

Incident Response

Detecting, responding to, and recovering from incidents.

CISOActive
P05 · Vendor

Third-Party Risk Management

Assessing and managing risk from outside vendors.

VP ProcurementActive
P06 · Operations

Business Continuity

Keeping critical functions running through a disaster.

COOActive
P07 · Data Mgmt

Data Retention & Disposal

How long data is kept and how it's destroyed.

Chief Data OfficerActive
P08 · HR

Acceptable Use

How employees may use company IT resources.

VP of HRActive
P09 · Operations

Change Management

How changes to IT systems are approved and made.

VP of EngineeringActive
P10 · Finance

Financial Reporting Controls

Internal controls ensuring accurate financial reports (SOX).

CFOActive
P11 · Security

Cloud Security

Security requirements for cloud infrastructure.

CISODraft
P12 · Technology

AI Governance

Ethical development & deployment of AI — parent of all 12 AI controls.

CTOUnder Review
Why this register matters

Ten policies are Active; two aren't. The AI Governance Policy (P12) is only Under Review — yet it's the parent of every AI control. An un-ratified policy can't compel a control, so this single un-approved status is the root cause of the AI failures you'll see in every register below. Teaching point: governance maturity is visible in the status column before you read anything else.

2
The register of mechanisms · 35 entries

Controls

The actual safeguards — grouped under the policy that authorizes each.

Each control has a type (Preventive / Detective / Corrective) and two health checks: does it exist (implementation) and does it work (effectiveness)? Expand each policy to see its controls. The contrast between the mature groups and the AI group is the whole story.

Data Protection & Privacy controls 1–5 · policy P01
C1Data Classification · label data by sensitivityPreventiveEffective
C2Data Encryption at Rest · AES-256PreventiveEffective
C3Data Encryption in Transit · TLS 1.2+PreventiveEffective
C4Consent Management · track consent for processingPreventivePartially Effective
C5DSAR Process · handle data-subject requests in 30 daysCorrectiveEffective
Access Control controls 6–9 · policy P03
C6Multi-Factor Authentication · MFA on productionPreventiveEffective
C7Role-Based Access Control · least privilegePreventivePartially Effective
C8Quarterly Access Reviews · managers re-certify accessDetectiveEffective
C9Privileged Access Management · PAM + session recordingPreventivePartially Effective
Incident Response controls 10–12 · policy P04
C10Security Event Monitoring · 24/7 SIEMDetectiveEffective
C11Incident Response Playbooks · top-10 incident typesCorrectiveEffective
C12Post-Mortem Process · within 5 days of closureCorrectivePartially Effective
Third-Party Risk controls 13–15 · policy P05
C13Vendor Security Assessment · pre-onboarding reviewPreventiveEffective
C14Vendor Continuous Monitoring · ongoing scanningDetectiveNot Assessed · Planned
C15Contractual Security Requirements · clauses in contractsPreventiveEffective
Business Continuity controls 16–18 · policy P06
C16Disaster Recovery Plan · RPO<4h, RTO<8hCorrectiveEffective
C17Annual DR Testing · full failover testDetectivePartially Effective
C18Backup Verification · weekly restore checksDetectiveEffective
Change Management controls 19–20 · policy P09
C19Change Advisory Board · reviews significant changesPreventiveEffective
C20Automated Deployment Pipeline · CI/CD with test gatesPreventiveEffective
Financial Reporting controls 21–23 · policy P10
C21Segregation of Duties · no single-person transactionsPreventiveEffective
C22Financial Close Reconciliation · within 5 daysDetectiveEffective
C23Journal Entry Approval · manager sign-offPreventiveEffective
AI Governance controls 24–35 · policy P12 — the immature group
Not one of these 12 is Implemented & Effective. This is the entire risk story in one group.
C24AI Model Risk Assessment · classify risk tier before deployPreventivePlanned
C25AI Bias Testing · fairness testingDetectivePlanned
C26AI System Registration · EU database (Art. 71)PreventiveNot Implemented
C27AI Transparency & Explainability · explain decisionsPreventivePartially
C28AI Human Oversight Mechanism · override / interrupt (Art. 14)PreventivePartially
C29AI Data Governance · training-data quality (Art. 10)PreventivePlanned
C30AI Conformity Assessment · pre-market verification (Art. 43)PreventiveNot Implemented
C31AI Incident Reporting · report within 15 days (Art. 73)CorrectiveNot Implemented
C32AI Technical Documentation · Annex IV dossierPreventivePartially
C33AI Fundamental Rights Impact Assessment · FRIA (Art. 27)PreventiveNot Implemented
C34AI Post-Market Monitoring · watch drift & performanceDetectivePlanned
C35AI Lifecycle Compliance Tracking · cradle-to-graveDetectiveNot Implemented
Why this register matters

Read the pattern, not the rows: the seven traditional groups are dominated by Effective; the AI group has zero. Same company, same skill — simply never turned on AI. Also note P02 (Information Security), P07, P08, and P11 have no controls attached at all — a policy with no controls is unenforced intent, a coverage gap worth teaching.

3
The register of worry · 22 entries

Risks

What could go wrong — each scored Likelihood × Impact so it can be ranked.

Score bands: Low 1–5 Medium 6–11 High 12–19 Critical 20–25. AI-related rows are tinted. Notice how they crowd the top.

#RiskCategoryL×IScoreStatusOwner
16AI Act non-compliance — high-risk system · deploying without conformity assessmentAI Regulatory4×520 CriticalOpenCTO
18AI training-data bias & quality · discriminatory outcomesAI Governance4×416 HighOpenML Eng
20AI lifecycle compliance gap · no cradle-to-grave trackingAI Regulatory4×416 HighOpenAI Ethics Board
7Phishing campaign targeting executivesCybersecurity4×416 HighOpenCISO
11AI model bias in lending decisions · harms protected groupsTechnology3×515 HighOpenCTO
17AI lack of human oversight · consequential decisions uncheckedAI Governance3×515 HighOpenAI Ethics Board
22AI fundamental-rights violation · no impact assessmentAI Governance3×515 HighOpenCPO
1Data breach via third-party vendorThird-Party3×515 HighOpenCISO
2Ransomware attackCybersecurity3×515 HighMitigatedCISO
19AI transparency failure · can't explain decisionsAI Governance3×412 HighOpenML Eng
21Unregistered high-risk AI system · not in EU databaseAI Regulatory3×412 HighOpenAI Ethics Board
5Insider threat — data exfiltrationCybersecurity3×412 HighOpenCISO
12Supply-chain software vulnerabilityCybersecurity4×312 HighOpenVP Eng
15Third-party API data leakageThird-Party3×412 HighOpenVP Eng
3GDPR non-compliance fineRegulatory2×510 MedOpenCPO
9Privileged access abuseCybersecurity2×510 MedOpenCISO
10Business continuity plan failureOperations2×510 MedOpenCOO
8Regulatory change impactRegulatory3×39 MedAcceptedCPO
14Incomplete audit trailCompliance3×39 MedOpenCISO
4SOX material weaknessFinancial2×48 MedOpenCFO
6Cloud service provider outageOperations2×48 MedMitigatedCTO
13Employee data privacy violationData Privacy2×36 MedMitigatedVP HR
Why this register matters

Eight AI risks; every one lands High or Critical, and the single Critical (#16, score 20) is an AI risk. The status column tells the treatment story: most are still Open, only a few Mitigated, and #8 is consciously Accepted — a deliberate governance decision, not neglect. Teaching point: the score decides priority; the status decides what you did about it.

4
The register of plans · 28 entries

Risk Mitigations

The dated actions that reduce each risk — usually by building a control.

A mitigation links a risk to an action or control, picks a strategy (Avoid / Mitigate / Transfer / Accept), and carries a due date and status. The gap between “planned” and “completed” is where programs live or die. A few representative examples:

RiskMitigation actionVia controlStatus
R1 · Vendor breachVendor security assessment programC13Completed
R2 · RansomwareImmutable backups + DR planC16Completed
R5 · Insider threatMFA + user-behavior analyticsC6In Progress
R16 · AI Act non-complianceConformity-assessment procedures for high-risk AIC30Planned
R16 · AI Act non-complianceRegister AI systems in EU databaseC26Planned
R17 · No human oversightDeploy human-oversight mechanismsC28In Progress
R18 · Training-data biasAI data-governance framework + bias testingC29 · C25Planned
R19 · Transparency failureExplainability layer + Annex IV docsC27 · C32In Progress
R22 · Fundamental rightsConduct FRIA for all AI systemsC33Planned
Why this register matters

Of the 28 mitigations, the ones tied to traditional risks are frequently Completed; every mitigation tied to an AI risk is Planned or In Progressnever Completed. The intent is documented; the delivery is entirely outstanding. That plan-vs-done gap is the earliest, clearest signal of a program that's behind.

5
The register of proof · 18 entries

Audit Findings

Gaps an independent examiner found in a specific control — each owned and dated.

Every finding points at a control and carries a severity, a remediation owner, and a due date. Grouped by severity — the Criticals are the worklist that comes first.

Sev.FindingControlOwnerDue
CriticalNo conformity assessment completed for any AI system despite AI Act enforcementC30AI Ethics Board2025-09-01
CriticalNo AI system registration process for EU AI Act complianceC26AI Ethics Board2025-06-01
CriticalHuman override not available for AI credit-scoringC28AI Ethics Board2025-05-01
CriticalPAM not covering 3 legacy DB admin accountsC9Identity Team2025-01-31
CriticalSame person initiating & approving journal entriesC21Finance Ops2025-01-31
HighNo AI model risk-assessment framework (3 models live)C24AI Ethics Board2025-06-01
HighChatbot gives no explanation for escalationC27ML Engineering2025-06-01
HighFraud-AI training data not assessed for biasC29Data Governance2025-07-01
HighNo fundamental-rights assessment for AI hiring toolC33AI Ethics Board2025-07-01
HighNo lifecycle compliance tracking for 5 AI systemsC35AI Ethics Board2025-09-01
HighConsent records missing for 12% of EU accountsC4Privacy Team2025-02-01
High15 dormant accounts with elevated privilegesC7Identity Team2025-02-15
HighNo continuous monitoring for 8 critical SaaS vendorsC14Vendor Risk2025-03-01
HighDR failover test excluded payment systemsC17Infrastructure2025-03-15
MediumPost-mortems done for only 60% of P1 incidentsC12SOC Team2025-03-01
MediumEmergency changes bypassing CI/CD up 40%C20DevOps2025-03-01
Medium23 data assets not yet classified per policyC1Data Governance2025-02-01
MediumQuarterly finance access review completed 2 weeks lateC8Identity TeamClosed
Why this register matters

Three of the five Critical findings are AI, and all point at controls that block deployment legality (conformity, registration, human override). Every AI finding is still Open. Teaching point: a finding's worth is the owned, dated commitment to fix it — the paperwork here is sound; the execution is late.

6
The register of evidence · 48 entries

Compliance Mappings

The crosswalk proving a control satisfies a specific legal requirement — with the evidence.

A mapping is a four-part link: a control, a framework requirement (e.g. “Art. 14”), a status, and — the field that decides everything — an evidence location. With 48 of them, don't read each; read the pattern. Compare a healthy mapping to a failing one:

ControlFramework · requirementStatusEvidence
C2 Encryption at RestGDPR · Art. 32 (Security)CompliantSharePoint/GRC/GDPR/Art32
C21 Segregation of DutiesSOX · §302CompliantSharePoint/GRC/SOX/Sec302
C6 MFAPCI DSS · Req 8.3CompliantSharePoint/GRC/PCI/Req8
C30 Conformity AssessmentAI Act · Art. 43Non-Compliant(null)
C29 AI Data GovernanceAI Act · Art. 10Non-Compliant(null)
C24 AI Risk ClassificationAICM · RM-01Non-Compliant(null)
C25 AI Bias TestingAIEU · FA-01 (Fairness)Non-Compliant(null)
C27 TransparencyAI Act · Art. 13PartiallySharePoint/GRC/AIAct/Art13

Across all 48: the 6 traditional frameworks (GDPR, SOX, HIPAA, ISO 27001, PCI, NIST) are almost entirely Compliant with real evidence paths. The 22 mappings to AI frameworks (AI Act, AICM, AIEU) are all Partial or Non-Compliant — and every Non-Compliant one has a null evidence field.

Why this register matters

This is where the hardest truth in GRC becomes a single column: compliance is what you can prove. A control that works but has no evidence attached counts, to an auditor, as non-compliant. The traditional rows point at documents and read green; the AI rows point at nothing and read red. Same firm — the difference is entirely whether a proof exists.


The chain, in one breath

How the six registers tell one story

Follow a single thread through all six for this firm's AI problem:

The AI Governance Policy is only Under Review (Register 1), so its AI controls were never built (Register 2), which is exactly why the AI risks score High and Critical (Register 3), whose mitigations are all still Planned (Register 4); an auditor independently flagged the same gaps as Critical and Open (Register 5), and the compliance mappings confirm it with a wall of Non-Compliant, evidence: null (Register 6).

One un-ratified policy, traced through six records, into a wall of red. That traceability — from intent to proof — is the entire value of keeping these registers. Fix the root (ratify the policy, fund the board) and the whole chain can turn green.

The five columns that carry the most meaning
  • Policy statusActive or not decides whether anything below it has authority.
  • Control effectivenessEffective (tested) is a different fact from Implemented (exists).
  • Risk score & status — the number sets priority; the status shows the treatment decision.
  • Finding due-date + owner — turns a discovered gap into a tracked commitment.
  • Mapping evidence location — null means non-compliant, however good the intent.

The Operating Registers — a teaching guide to the six internal GRC records (policies, controls, risks, mitigations, audit findings, compliance mappings) in the project database. Companion to “The Regulatory Atlas,” “The Seven Building Blocks of GRC,” and the practitioner course “GRC for Generative AI.” All data is synthetic teaching material; examples are illustrative, not legal advice.