Christophe MontagneInterim CTO · Advisory

Beyond the Demo/2 min read

03Governance first, kept light

A skeleton of governance set up in weeks: a map of uses, a map of data, and what cannot wait.

Before the first cycle, the organisation needs a skeleton of governance. Not a complete programme, which comes with experience, but a few major guardrails, set up in weeks rather than months and refined by the projects themselves. Figure 4 shows its shape: three tiers, applied to uses and to data.

Off limits Handle with care Low risk: start here USES what the AI is used for DATA what goes into it Practices banned by law, such as social scoring or emotion recognition at work What the company itself refuses to do Decisions about employees or candidates, credit, essential services Safety-critical answers Possible, but not a first project Internal assistants, documentation search, drafting reviewed by people Users know they are dealing with AI Data that must never leave the company or be processed by AI, under any condition Personal, client, health or supplier-confidential data Specific hosting, contracts and access rules required Public or non-sensitive internal documents Each project, and each body of documents, is placed on the map before the first cycle. The map is refined as projects teach the organisation.
Figure 4. A skeleton of governance: the same three tiers for uses and for data.

A map of uses

  • Off limits. In Europe, for instance, the AI Act has banned practices such as social scoring and emotion recognition in the workplace since February 2025. Each organisation adds what it refuses to do.
  • Handle with care. Decisions about employees or candidates, credit, access to essential services, safety in critical infrastructure. Possible, but not first projects.
  • Low or limited risk. Most internal assistants, provided users know they are dealing with AI. This is where to start.

A map of data

Here GenAI raises questions classic projects did not. Your data leaves the building: every question sends passages of your documents to the model, and if a third party hosts it, your knowledge passes through its infrastructure, possibly outside your jurisdiction. Contracts must settle training use, retention and location; hosting the model yourself is an option, with its own costs. It is a business decision, not a technical default. The index is a new copy of your knowledge, to be protected at the level of the most sensitive document it contains, and deleting a source does not delete what was extracted from it. Answers can bypass access rights, drawing on documents a user could never open, or combining harmless passages into something that is not. Even the log of questions is sensitive: it shows what each employee is doing.

Which rules apply depends on the data, and legal must map them before anything is loaded. Our rail maintainer's documents look harmless, yet include supplier documentation under licence, incident reports and personal data in technicians' notes. In a bank, a hospital or a law firm, the same project would handle client files, patient records or privileged correspondence.

What cannot wait, and what must not become an excuse

Some obligations already apply: in Europe, the AI Act has required since February 2025 an adequate level of AI literacy among staff who use AI. And employees are probably already pasting company documents into public chatbots; a simple rule on approved tools and on data that must never leave the company may be the most urgent part of the skeleton. But "governance first" must not become the new reason to wait. A skeleton, quickly; then start.

Where our example sits

Our rail maintainer's assistant advises a human and decides nothing on its own, which probably keeps it out of the heaviest regulatory categories. But rail is critical infrastructure, and some answers are safety-critical. Legal must assess it, and those questions belong in "handle with care."

The data calls for decisions too. Supplier documents under licence or NDA are kept out of the first stages: the documentation audit and the first assistant work on the company's own documents only. Whether supplier documents can enter later depends on each contract, and may require hosting the model in-house. Some may never enter at all; the system can still point technicians to them without reading them.

Applied honestly, governance shapes the project: the first stage puts no answers in technicians' hands at all, and safety-critical answers come last, if ever. Chapter 05 shows the resulting sequence.