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For Compliance and General Counsel

A policy you cannot evidence is a promise.

Show the regulator a rule, a record and a named owner, before they ask.

Your business uses AI in drafting, customer contact, hiring support and analysis. You are asked to evidence control over all of it. A written policy cannot show that a rule was followed, by whom, on what data.

63%

of UK organisations in IBM's study had no AI access controls (vendor research, 2025).

IBM Cost of a Data Breach, UK, 2025
53%

of organisations with AI agents say an agent has exceeded its permissions (vendor-sponsored survey of 445 organisations).

Cloud Security Alliance and Zenity, April 2026
46%

of UK financial services firms using AI say they only partly understand it.

Bank of England and Financial Conduct Authority, 2024
What you are carrying

Six problems that reach your desk, in the words they usually arrive in.

63%

of UK organisations in IBM's study had no AI access controls, so a written rule had nothing behind it.

IBM, UK, 2025 (vendor research)
"The rules changed and the guidance is still moving."

The Data (Use and Access) Act 2025 widened the rules on automated decisions, and the ICO must produce a statutory code on AI and automated decisions (regulations in force 12 May 2026). What it costs you: a standing review burden with no fixed target.

"I cannot say which tools hold personal data."

Without a current list and a map of data flows, impact assessments are written from memory. What it costs you: assessments that do not match reality, and exposure you cannot size.

"Someone clicked approve without really checking."

The ICO has said that approving an AI-generated ranking without independent analysis is not meaningful human involvement (Recruitment Rewired, March 2026). What it costs you: a human step that does not count as one.

"The insurer and the client want evidence, and we build it by hand."

Each request means gathering screenshots, policies and emails. What it costs you: specialist time, inconsistent answers and delay.

"Our own people cited something that did not exist."

Courts and regulators have acted on invented citations. The High Court's June 2025 judgment on fabricated authorities referred lawyers to their regulators. What it costs you: personal and professional exposure.

"Agents act, and I cannot see what they did."

Agents are given access to systems and then act on their own. The National Cyber Security Centre advises scoped credentials, logging and the ability to stop an agent. What it costs you: actions with no owner and no record.

A different way to look at it

Regulators have moved from asking whether you have a policy to asking how it behaved.

The questions now are practical. Did a person see the inputs before approving the output? Was the risk assessed before switch-on? Can you show it? Most businesses can show the first of three things, a rule. Few can show the second, a record that it was followed, or the third, a named person who owns it. The task is less to write more policy than to put the rule where the work happens and keep the record as a by-product.

Compiled from ICO, Financial Conduct Authority and Solicitors Regulation Authority statements, 2025 to 2026. This is a view, not legal advice.

How GenWA helps

Guard and Evidence work as a pair: rules enforced, and the record that proves it.

Rules and Log are in early access. Evidence Packs and Compliance Mapping are available. We confirm in writing what you receive.

How it works

Documents are generated alongside AI use, and flagged to a person for approval.

The record is produced as the work happens, and anything consequential waits for a named approver.

Four steps in order: a document is generated alongside AI use, flagged, approved by a person, and recorded.

  1. 1Document generated

    A record is produced alongside the AI use, as the work happens.

  2. 2Flagged

    Anything that needs a decision is sent to the person who owns it.

  3. 3Approved by a person

    A named person approves, changes or rejects it. AI does not sign off.

  4. 4Recorded

    The decision, the approver and the date are kept with the document.

GenWA Guard and Evidence. Steps shown in order.
Where to start

Three moves for Compliance and General Counsel.

Step 1List what is in use. Ask for every AI tool, account and feature, who owns it and what data it touches.
Step 2Pick the rules that matter most. Start with the data that must not leave and the work where AI must not be used.
Step 3Ask for the evidence view. See the pack your next audit, insurer or tender would receive, then close the gaps.
Ways of working with us

Three routes, matched to how your team works.

Bring them with you

The three colleagues who make the evidence real.

Chief risk officer

Owns the risk appetite the rules express and reviews the exception log.

Data protection officer

Owns impact assessments and the data-flow map, and checks what is held back.

Chief information officer

Connects the systems so the rules apply and the record is complete.

For the CTO and CIO
Public incident

A chatbot invented a refund policy, and the airline was held to it.

In 2024 a Canadian tribunal ruled that Air Canada was responsible for wrong information given by its website chatbot, which had invented a bereavement refund rule. The airline had argued the bot was a separate entity. The tribunal disagreed. The lesson for a compliance lead is that accountability stays with the business, and a record of what the system was allowed to say would have been the starting point.

Moffatt v Air Canada, 2024 BCCRT 149 (British Columbia Civil Resolution Tribunal). Public incident. GenWA had no involvement.

Want to see an evidence pack?

Book a demo and we will walk through a pack built from example data.

Questions we are asked

Straight answers.

How can I evidence AI controls to a regulator, insurer or auditor?

Show three things: an enforced rule, a record that it was followed and a named owner. GenWA produces Evidence Packs from the record, control-mapped to ISO/IEC 42001, UK GDPR and the 2025 Act, SOC 2 and Cyber Essentials. The regulator or auditor decides what is sufficient.

What is in an Evidence Pack?

A register of AI in use, a data-flow map, a control matrix showing whether each control is working, and an exception log of breaches, blocks and overrides with owners. The pack is produced for the period or process requested rather than rebuilt for each request.

Will an auditor accept evidence that comes from a vendor?

It is a record of your own rules, approvals and exceptions, laid out so a reviewer can follow it. The auditor decides what is sufficient. We prepare the evidence; accredited bodies issue certification, and GenWA does not hold or claim any.

Does GenWA replace our governance, risk and compliance tool?

No. Keep it. Evidence Packs are designed to be used alongside it. Whether and how they connect to a specific tool is confirmed with our technical team before we promise anything.

What does the Data (Use and Access) Act change for AI?

It widened the rules on automated decisions, with safeguards such as being told, contesting and meaningful human involvement. The ICO has a duty to produce a code on AI and automated decisions. Check dates and detail with your own legal adviser.

Does GenWA use AI to make decisions about people?

No. AI is not used for decisions on credit, hiring or medical matters. People decide. AI can prepare material, and the approval is recorded with the name of the person who gave it.

What is live today and what is still being built?

Evidence Packs and Compliance Mapping are available. Rules and Log are in early access. Plain-English rule writing and tested model switches are being built next. We confirm in writing what you receive and do not describe a building item as live.