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AI Compliance Checklist

Reference

Purpose: Ensure AI projects comply with Australian Government requirements, legislation, and frameworks. Use throughout the project lifecycle to verify compliance and document evidence.
Checklist Coverage
  • Ethics: All 8 AI Ethics Principles
  • Privacy: Privacy Act, APPs
  • Security: PSPF, ISM requirements
  • Accessibility: WCAG, DTA standards

Living Document

This checklist should be maintained throughout your project. Review at each phase gate and update as requirements change.


How to Use This Checklist

  1. Complete relevant sections based on project phase
  2. Document evidence for each item
  3. Escalate any gaps to appropriate stakeholders
  4. Review with governance bodies as required
  5. Maintain as a living document

Compliance Status: - [ ] Not Started - [~] In Progress - [x] Complete - [N/A] Not Applicable


Section 1: Australian Government AI Ethics Framework

1.1 Human, Societal and Environmental Wellbeing

# Requirement Status Evidence Notes
1.1.1 Benefits and risks to individuals assessed [ ]
1.1.2 Societal impacts considered [ ]
1.1.3 Environmental impact assessed [ ]
1.1.4 Net benefit demonstrated [ ]

1.2 Human-Centred Values

# Requirement Status Evidence Notes
1.2.1 Respects human rights [ ]
1.2.2 Respects diversity [ ]
1.2.3 Supports individual autonomy [ ]
1.2.4 User research conducted [ ]

1.3 Fairness

# Requirement Status Evidence Notes
1.3.1 Bias testing conducted [ ]
1.3.2 Fairness metrics defined and met [ ]
1.3.3 Inclusive design applied [ ]
1.3.4 Discrimination risks mitigated [ ]

1.4 Privacy Protection and Security

# Requirement Status Evidence Notes
1.4.1 Privacy Impact Assessment completed [ ]
1.4.2 Data minimization applied [ ]
1.4.3 Security assessment completed [ ]
1.4.4 Access controls implemented [ ]

1.5 Reliability and Safety

# Requirement Status Evidence Notes
1.5.1 Testing comprehensive [ ]
1.5.2 Monitoring implemented [ ]
1.5.3 Fallback mechanisms in place [ ]
1.5.4 Safe failure modes defined [ ]

1.6 Transparency and Explainability

# Requirement Status Evidence Notes
1.6.1 AI use disclosed to affected people [ ]
1.6.2 Explanations available [ ]
1.6.3 Model card completed [ ]
1.6.4 Limitations documented [ ]

1.7 Contestability

# Requirement Status Evidence Notes
1.7.1 Challenge mechanism exists [ ]
1.7.2 Human review available [ ]
1.7.3 Appeal process documented [ ]
1.7.4 Contact point identified [ ]

1.8 Accountability

# Requirement Status Evidence Notes
1.8.1 Clear ownership assigned [ ]
1.8.2 Governance structure in place [ ]
1.8.3 Audit trail maintained [ ]
1.8.4 Responsibility for outcomes clear [ ]

Section 2: Privacy Act 1988 Compliance

2.1 Australian Privacy Principles (APPs)

APP Requirement Status Evidence Notes
APP 1 Open and transparent management of personal information [ ]
APP 2 Anonymity and pseudonymity options [ ]
APP 3 Collection of solicited personal information [ ]
APP 4 Dealing with unsolicited personal information [ ]
APP 5 Notification of collection [ ]
APP 6 Use or disclosure of personal information [ ]
APP 7 Direct marketing restrictions [ ]
APP 8 Cross-border disclosure of personal information [ ]
APP 9 Adoption, use or disclosure of government identifiers [ ]
APP 10 Quality of personal information [ ]
APP 11 Security of personal information [ ]
APP 12 Access to personal information [ ]
APP 13 Correction of personal information [ ]

2.2 Privacy Assessment

# Requirement Status Evidence Notes
2.2.1 Privacy threshold assessment completed [ ]
2.2.2 PIA completed (if required) [ ]
2.2.3 Privacy risks documented [ ]
2.2.4 Privacy controls implemented [ ]
2.2.5 Privacy notice updated [ ]

Section 3: Protective Security Policy Framework (PSPF)

3.1 Information Security

# Requirement Status Evidence Notes
3.1.1 Information classified correctly [ ]
3.1.2 Handling requirements met [ ]
3.1.3 Access controls appropriate [ ]
3.1.4 Transmission security adequate [ ]

3.2 Personnel Security

# Requirement Status Evidence Notes
3.2.1 Staff clearances appropriate [ ]
3.2.2 Vendor personnel cleared [ ]
3.2.3 Training completed [ ]

3.3 Physical Security

# Requirement Status Evidence Notes
3.3.1 Physical access controlled [ ]
3.3.2 Equipment secured [ ]

Section 4: Information Security Manual (ISM)

4.1 General Controls

# Requirement Status Evidence Notes
4.1.1 Risk assessment completed [ ]
4.1.2 Security plan documented [ ]
4.1.3 Incident response plan in place [ ]

4.2 Access Control

# Requirement Status Evidence Notes
4.2.1 Principle of least privilege applied [ ]
4.2.2 Multi-factor authentication (where required) [ ]
4.2.3 Access reviews scheduled [ ]

4.3 Software Security

# Requirement Status Evidence Notes
4.3.1 Secure development practices [ ]
4.3.2 Code review completed [ ]
4.3.3 Vulnerability assessment done [ ]
4.3.4 Penetration testing (if required) [ ]

4.4 Data Security

# Requirement Status Evidence Notes
4.4.1 Data encrypted at rest [ ]
4.4.2 Data encrypted in transit [ ]
4.4.3 Key management in place [ ]
4.4.4 Data backup and recovery [ ]

4.5 Network Security

# Requirement Status Evidence Notes
4.5.1 Network segmentation [ ]
4.5.2 Firewall rules documented [ ]
4.5.3 Intrusion detection/prevention [ ]

Section 5: Digital Service Standard

5.1 User-Centred Design

# Requirement Status Evidence Notes
5.1.1 User needs researched [ ]
5.1.2 User testing conducted [ ]
5.1.3 Iterative development [ ]
5.1.4 Feedback mechanisms in place [ ]

5.2 Accessibility (WCAG 2.1)

# Requirement Status Evidence Notes
5.2.1 WCAG 2.1 AA compliance [ ]
5.2.2 Accessibility testing completed [ ]
5.2.3 Assistive technology compatible [ ]

Section 6: Anti-Discrimination Legislation

6.1 Non-Discrimination

# Requirement Legislation Status Evidence
6.1.1 Age discrimination prevented Age Discrimination Act 2004 [ ]
6.1.2 Disability discrimination prevented Disability Discrimination Act 1992 [ ]
6.1.3 Sex discrimination prevented Sex Discrimination Act 1984 [ ]
6.1.4 Racial discrimination prevented Racial Discrimination Act 1975 [ ]
6.1.5 Indirect discrimination considered Various [ ]

Section 7: Administrative Law

7.1 Decision-Making Requirements

# Requirement Status Evidence Notes
7.1.1 Proper authority for decision [ ]
7.1.2 Relevant considerations applied [ ]
7.1.3 Irrelevant considerations excluded [ ]
7.1.4 Procedural fairness observed [ ]
7.1.5 Reasons for decision available [ ]
7.1.6 Review rights communicated [ ]

7.2 Automated Decision-Making

# Requirement Status Evidence Notes
7.2.1 Legal authority for automation [ ]
7.2.2 Human oversight appropriate [ ]
7.2.3 Manual override possible [ ]
7.2.4 Audit trail maintained [ ]

Section 8: Data Governance

8.1 Data Management

# Requirement Status Evidence Notes
8.1.1 Data ownership defined [ ]
8.1.2 Data quality standards met [ ]
8.1.3 Data catalogue entry created [ ]
8.1.4 Retention schedule applied [ ]
8.1.5 Disposal procedures in place [ ]

8.2 Data Sharing

# Requirement Status Evidence Notes
8.2.1 Data sharing agreements [ ]
8.2.2 Third-party access controlled [ ]
8.2.3 Cross-agency sharing authorized [ ]

Section 9: Cloud and Hosting

9.1 Cloud Security

# Requirement Status Evidence Notes
9.1.1 Cloud provider on approved list [ ]
9.1.2 Data sovereignty (Australian data centers) [ ]
9.1.3 Cloud security assessment [ ]
9.1.4 Shared responsibility understood [ ]

Section 10: Procurement and Contracts

10.1 Vendor Requirements

# Requirement Status Evidence Notes
10.1.1 Vendor security assessment [ ]
10.1.2 Subprocessors documented [ ]
10.1.3 AI-specific contract clauses [ ]
10.1.4 Exit/transition provisions [ ]
10.1.5 IP ownership clarified [ ]

Summary Assessment

Compliance Status by Section

Section Items Complete In Progress Not Started N/A
AI Ethics Framework
Privacy Act
PSPF
ISM
Digital Service Standard
Anti-Discrimination
Administrative Law
Data Governance
Cloud Security
Procurement
TOTAL

Outstanding Items

Item Owner Due Date Priority
High/Med/Low

Risk Assessment

Gap Risk Level Mitigation Timeline
High/Med/Low

Sign-Off

Role Name Date Sign-Off
Project Manager [ ]
Privacy Officer [ ]
Security Officer [ ]
Legal Counsel [ ]
Ethics Lead [ ]

Version History

Version Date Author Changes
1.0 Initial checklist