AI and privilege after United States v. Heppner: what legal teams should know. Read the analysis →
Challenges · 04 of 06 · Compliance with frameworks

Every framework asks the same question: show us the control operating.

ISO 42001, SOC 2, the EU AI Act, and GDPR each want a policy for AI, a control that enforces it, and evidence that the control ran. Most companies have the policy. The Privilege AI Agent is the control, and the ledger is the evidence.

FrameworksISO 42001 · SOC 2 · EU AI Act · GDPR
Readiness78% not confident of passing in 90 days
Hit hardestCompliance · GRC · Privacy · Audit
Governed by03 Agent · 01 Privilege AI · 02 Watch
What is at stake

A policy on a wiki is not a control.

AI governance under ISO 42001 means an AI management system: documented roles, approved use cases, impact assessments, and monitoring that proves the rules are followed. SOC 2 asks for the same discipline over confidentiality. The EU AI Act adds record-keeping and human oversight. GDPR adds lawful basis, processors, and retention.

What auditors reject is the gap between the policy and the workstation: an approved-tools list with no enforcement, an AI register nobody updates, exceptions granted in chat. What they accept is evidence generated automatically, by a control that was running the whole time.

AI management systemControl evidenceException register
78%of executives lack strong confidence they could pass an AI governance audit within 90 days.Grant Thornton · 2026
48%of breaches involve a third party — up 60% — the processor question every framework asks.Verizon · 2026 DBIR
3.2%of DLP violations involved research or technical documents uploaded to unauthorized AI.Verizon · 2026 DBIR
Framework map

What each framework wants, and what produces it.

ISO 42001AI management system

Roles, approved use cases, impact assessment, monitoring, continual improvement.

→ Agent · monitoring evidence→ Privilege AI · use-case registry by matter→ Watch · exception reporting
SOC 2Confidentiality · processing integrity

Controls over how confidential data is classified, transferred, and disposed of — and proof they operated across the period.

→ Agent · DLP-grade transfer control→ Ledger · SHA-256 hash-chained→ Watch · period-of-review reports
EU AI ActRecord-keeping · human oversight

Logs of what the system did, transparency about which model answered, and a human with authority over the outcome.

→ Privilege AI · model, citations, who was present→ Counsel in the session · human oversight→ Agent · device-level record
GDPRLawful basis · processors · retention

Who processes personal data, under what agreement, for how long — and the ability to show it on request.

→ Bring your own OpenAI / Anthropic keys→ Retention and legal hold per matter→ Agent · unapproved processor detection
Where it shows up

The people who have to produce the evidence.

Compliance & Risk · GRC / Compliance AnalystPrepares assessments and control evidence with AI.Exposure: security reports and personal evidence analyzed in an unapproved AI system; confidentiality breach and regulatory risk.01 Privilege AI · 03 Agent
Compliance & Risk · Privacy / AI Risk OfficerEvaluates AI vendors, data flows, and permitted processing.Exposure: no consistent approval, retention, or data-purpose review for AI tools; inconsistent lawful processing.03 Agent · 02 Watch
Compliance & Risk · Enterprise Risk / AI Governance LeadReports AI risks, exceptions, and control operation to leadership.Exposure: leadership receives incomplete adoption, exposure, and exception reporting; undetected control failures.02 Watch · 03 Agent
Procurement · Vendor Risk ManagerReviews vendor DPAs, SOC reports, and AI supplier agreements.Exposure: a new AI supplier processes counterparty data before due diligence or approval; vendor-driven exposure and remedial expense.03 Agent
Legal · Legal Operations ManagerSets and reviews permitted AI workflows and exception requests.Exposure: legal use of AI has no owner, approval record, or restriction catalogue; professional-duty exposure.01 Privilege AI
Operations · Operations DirectorReviews AI usage, rollout, and benefit by function.Exposure: management cannot connect AI adoption to actual business use or risky data flows; unnoticed leaks and unmanaged vendors.02 Watch
How Privilege AI governs it

The control, the record, and the report.

03 · Privilege AI AgentPrimary
The control that was running the whole time.

Provides monitoring evidence for review within your compliance program: 120+ categories of violation detected at the workstation, every event alerted to legal and compliance with evidence an auditor can sample.

Privilege AI Agent
01 · Privilege AI
The record.

Every answer carries its model, its citations, and who was present, in a SHA-256 hash-chained ledger — the record-keeping and human-oversight evidence the EU AI Act and ISO 42001 describe.

Privilege AI
02 · Privilege Watch
The report.

Detections, exceptions, and approvals summarized for legal, compliance, and the audit committee — adoption, exposure, and control operation in one view.

Privilege Watch
Models · Claude Fable 5.1 · Claude Opus 5.5 · ChatGPT Astra 6Bring your own keys or use a system key0 matters trained on
United States v. Heppner · AI & legal privilege

Make AI governance visible in the work.

Legal review and compliance programs both benefit from clear ownership, approved uses, and evidence of what happened. Privilege AI’s matter records, Watch review queues, and Agent detections can support that operating process. Heppner supplies the privilege context; your obligations under each applicable framework require their own assessment.

Executive sponsorChief Compliance Officer · CISO · DPO
Decision makerCISO or Chief Compliance Officer · CIO co-sponsor
StakeholdersRisk · Internal audit · Board / Audit committee · Legal · Privacy

Pass the AI governance audit
with evidence, not promises.