ISO 42001 Responsible AI Use: Processes, Objectives and Intended Use

Approve a use, not merely a product name

A tool can support several tasks with very different consequences. Drafting an internal meeting agenda, analysing a customer complaint and influencing a consequential decision are not equivalent simply because the same interface is involved. Define the intended task, users, information, operating conditions and role of the output before deciding what use is acceptable.

The use process should connect with relevant procurement, information handling, security, privacy, quality and other arrangements. Existing processes may provide much of the necessary structure. Check whether they address the actual AI decision and whether people know how to apply them. A new AI form that duplicates existing approvals without closing a gap adds work rather than governance.

Consider ongoing needs as well as initial access. Who supports users, monitors relevant issues, maintains instructions and evaluates a changed use? What happens if the supplier changes the service or the required resources become unavailable? A.9.2 supports defined and documented processes that can address these questions in the organisation's context.

Set responsible-use objectives that influence behaviour

A.9.3 concerns documented objectives for responsible use and mechanisms to achieve them. Start with the purpose, risks, impacts and relevant obligations. An objective might concern maintaining meaningful review for a particular task, preventing use beyond evaluated conditions or enabling users to raise concerns. These examples are possible choices, not a compulsory list for every organisation.

Make the connection between an objective and the operating arrangement visible. If an objective depends on human oversight, determine what the person reviews, what information is available, what authority they have and what happens when they disagree with the output. A person who cannot understand or influence the decision does not provide meaningful oversight merely by being named in a procedure.

Account for workload and competence. A review step that is credible in a demonstration may fail under normal operating conditions. Test whether the expected action is realistic. Training can support understanding, but attendance alone does not establish that users can recognise the relevant limitation or respond appropriately.

Illustrative construction example: a new use of a familiar assistant

A construction consultancy approves an AI assistant for drafting routine internal text. A project team later wants to use the same assistant to summarise technical correspondence and identify contractual implications. The team sees this as a small extension because the software is already approved. The governance question is whether the new task, information and consequences fit the approved use.

The organisation routes the proposal through its use process. Relevant project, information and specialist functions assess the intended role and limitations. If a supported use is agreed, instructions explain what the output can contribute and which decisions remain with competent people. The approval does not represent legal advice from the tool or establish that a generated interpretation is correct.

Users are given a practical escalation route when an output appears inconsistent with project knowledge. The organisation checks whether the instructions are usable and whether the new workflow creates inappropriate reliance. This is more effective than simply repeating that “AI may make mistakes” while leaving the task boundary undefined.

Illustrative BPO example: review that must work under pressure

A BPO provider permits an AI assistant to suggest responses for service agents. The responsible-use objective is to support accurate, appropriate responses while retaining a defined review role. During a pilot, experienced agents can review drafts carefully. At peak workload, less experienced staff may accept fluent suggestions without checking the relevant customer information.

The provider evaluates the actual operating conditions. It examines the task, available evidence, staff competence, workload and escalation arrangements. The response may involve changing the supported use, improving instructions, adjusting the workflow or obtaining further evaluation. These are implementation options to assess, not a universal prescription for staffing or review intensity.

The organisation then checks whether the chosen arrangement works in practice. User feedback and selected case reviews can show whether the objective is being achieved. If the process relies on an action staff cannot realistically perform, the organisation should reconsider the arrangement rather than treating noncompliance as solely an individual failure.

Recognise changes in intended use

A.9.4 concerns using the system according to its intended purpose and relevant supporting information. Intended use is not just a sentence written at acquisition. It should remain understandable to users and owners as the tool, data and business process change. Identify what counts as a material extension requiring review.

Examples can include a new population, a different decision, another information category or a higher degree of automation. These are not automatically prohibited changes. They are reasons to determine whether the existing evidence and controls remain suitable. Avoid assuming that a technically possible use is already within the authorised boundary.

Even use within the stated boundary can reveal problems. Provide a route to report concerns internally and, where appropriate, to the supplier. Retain relevant evidence according to the organisation's needs and obligations. Correct use of an application does not guarantee that every output or effect will be acceptable.

Connect users with operational owners

Users need a clear point of contact for support, limitations and proposed changes. Owners need information from use to understand whether assumptions remain valid. This relationship connects A.9 with operation and monitoring and user information. It should not depend on users finding an informal expert who happens to know the system.

Where the system is supplied externally, determine what support and information the supplier provides and what the organisation must do itself. A supplier may explain capabilities and limitations, but the customer still needs to govern its own workflow and responsibilities. Use the external-relationship controls to clarify that boundary.

Keep a route for improvement. Repeated user confusion may indicate unclear instructions, unsuitable design, inadequate competence or a mismatch between the approved use and actual work. Investigate the pattern rather than assuming that another awareness message will resolve it. The appropriate action should address the cause supported by evidence.

Evidence that use is governed

Useful evidence can include defined use processes, documented objectives, approvals, current instructions, competence information and records of relevant changes or concerns. The form can vary. A separate register of approved uses may help, but the control does not prescribe that exact document name or require a particular software product.

Review a sample of actual use against its stated purpose. Ask a user to explain the tool's role, a relevant limitation and what they would do with a doubtful output. Then ask the owner how a new use is assessed. These suggested checks reveal whether the process is understood and connected, rather than merely distributed.

Common weaknesses include approving a brand instead of a task, treating all human involvement as effective oversight, neglecting supplier changes and assuming that a signed acceptable-use policy proves competent use. Another is measuring adoption alone while overlooking whether the system supports the intended outcome. Higher usage is not automatically evidence of responsible use.

Individual controls in this theme

Why responsible AI use controls matter to the business

Buying or building an AI tool is only the beginning. The harder question is what the organisation will actually allow it to do, who is accountable and what happens when people stretch it. The three controls in this group cover the process for deciding on use, the objectives that make responsibility concrete and the discipline of staying within intended use. For a business, the payoff is fewer unapproved workarounds, clearer accountability to clients and a better record when a decision is later questioned. Auditors read this group to see whether approval attaches to a specific purpose and whether oversight is real under normal workload, not merely listed in a procedure.