Sample deliverable. The firm and vendor are made up. Nothing is collected or sent.

AI governance
program

Folio Alder Bookkeeping

The staff policy, hiring review and working records for a 30-person accounting and bookkeeping firm in the Chicago suburbs.

Step one: see the Shadow AI audit sample

Program at a glance

Each part has an owner and a next step.

Staff policy

The rule staff receive and sign.

Download policy text

AI use policy

Folio Alder Bookkeeping · Version 1.0 · Issued October 30, 2026

This policy applies to all staff and contractors using AI for firm work. The managing partner owns the policy. The office lead keeps the approved-use register and staff acknowledgments.

Use only approved work accounts

The work-account chat assistant and office-suite AI writing feature may draft public-facing templates from public or invented material. The meeting note taker may summarize internal administration meetings only when everyone present agrees and no client or personnel matters are discussed. Disable automatic joining and check every summary. Do not use personal accounts.

AI features inside tax software stay disabled. Trellis Quoin Systems applicant ranking stays paused. Use the existing non-AI tax workflow and a person-led hiring review. A new feature is a new use and needs approval before it is enabled.

Keep restricted data out

Never enter client tax records, Social Security numbers (SSNs), bank details, passwords, payroll files, applicant records or other personal or confidential information into any AI tool. This includes uploads, prompts, connected folders and recorded meetings. Use invented examples. An approval for a tool does not override this rule.

Review before sending

A staff member must check every AI-assisted message or document before it goes to a client. Verify facts, calculations, sources and tone against the original records outside the AI tool. The engagement lead approves client tax or financial guidance. Do not send output you cannot verify. A person makes every hiring decision using the agreed job criteria.

Request a tool or report a problem

Send the office lead the proposed tool, task, data types, account plan and business owner. Wait for the managing partner's written approval and a register update before use. If output is wrong or data may have been exposed, stop the use and tell the office lead immediately. If unavailable, contact the managing partner. Record the tool, time and what happened without copying sensitive data into the report. The office lead opens an incident record and coordinates containment and review.

I have read this policy, understand the approved uses and know how to report a problem.

Staff signature

Date

Hiring assessment

Applicant tracking system: AI ranking

Assessment H-01 · October 30, 2026

Ranking stays paused

Applicants receive a person-led review against the written job criteria while evidence is incomplete.

People affected: Applicants for bookkeeping and accounting roles, plus staff reviewing applications.
Proposed purpose: Order applications for review. Do not reject, shortlist or make an offer automatically.
Scope: Resume and job-description matching. No video, voice or personality analysis.

Assessment record: harms, checks and remaining evidence
Possible harm	How it could happen	What the firm checks	Evidence state
Qualified applicants missed	Gaps in employment history or unfamiliar job titles could lower a ranking.	Compare rankings with a blind, person-led review against the same written job criteria. Review every disagreement.	Not tested
Proxy discrimination	Location and school history could stand in for protected characteristics.	Obtain the input dictionary. Exclude zip codes from ranking inputs and test paired invented applications that differ only in location.	Vendor evidence missing
False precision	A recruiter could treat a rank as a fact and overlook the original application.	Keep ranking off. Require a written human decision reason tied to the job criteria, with no automatic rejection.	Manual route set
Applicant data exposed	Resumes could be retained, reused or shared beyond the agreed purpose.	Confirm deletion, training exclusions and subprocessors before any applicant data reaches the ranking feature. Use invented test records.	Terms incomplete

Release decision

The hiring lead runs the comparison and signs the findings. The office lead verifies settings and records. Employment counsel reviews the hiring workflow and notice. The managing partner alone may approve a change to the hold after all gaps are resolved. Until then, no applicant data enters the ranking feature.

Decision recorded: managing partner, October 30, 2026. Next check: November 13, 2026. No test result or approval to resume is recorded.

Vendor review

Trellis Quoin Systems · Applicant ranking

Review V-01 · Follow-up November 6

Questions sent October 26, 2026. The response register distinguishes what arrived from what still needs proof.

Vendor response register
Question sent	Evidence returned	Open gap	Follow-up owner and due date
What inputs determine the rank?	V-01: configuration guide, received October 27. It lists experience and skills fields.	No complete input dictionary or confirmation that zip codes cannot enter ranking.	Hiring lead · November 6
How was the ranking tested?	V-02: product overview, received October 27. It describes a ranking feature.	No role-specific validation, test method, disaggregated results or independent evaluation. Marketing material does not close this gap.	Hiring lead · November 6
Can a person bypass the ranking?	V-03: admin walkthrough, received October 28. It shows a ranking-off switch and a manual review queue.	Firm-side verification and a saved configuration record are still due.	Office lead · November 6
What happens to applicant data?	V-04: draft data terms, received October 28. It describes a deletion request process.	No signed retention schedule, training exclusion, subprocessor list or deletion verification.	Managing partner · November 13
What changes will you tell us about?	V-05: response email, received October 29. It offers release notes.	No agreed advance notice for model, input or terms changes.	Office lead · November 13

Decision: keep ranking disabled. A product description is not evidence that this firm's use has been tested. Retain the questions and responses together in the evidence folder.

Illinois hiring rules

Public Act 103-0804 · 775 ILCS 5/2-102(L)

Effective January 1, 2026

The law says the following are civil rights violations. The checks beside the text are this firm's review steps.

AI and discrimination

Section 2-102(L)(1), including the zip code provision

"With respect to recruitment, hiring, promotion, renewal of employment, selection for training or apprenticeship, discharge, discipline, tenure, or the terms, privileges, or conditions of employment, for an employer to use artificial intelligence that has the effect of subjecting employees to discrimination on the basis of protected classes under this Article or to use zip codes as a proxy for protected classes under this Article."

What we check

Keep ranking off while the hiring lead tests it against the written job criteria. Ask for the input dictionary and testing evidence. Check that zip codes are excluded from ranking inputs and examine other possible proxies. Record disagreements between human review and AI rankings.

Open: complete inputs and role-specific testing evidence.

Notice

Section 2-102(L)(2)

"For an employer to fail to provide notice to an employee that the employer is using artificial intelligence for the purposes described in paragraph (1)."

Section 2-102(L), final paragraph

"The Department shall adopt any rules necessary for the implementation and enforcement of this subdivision, including, but not limited to, rules on the circumstances and conditions that require notice, the time period for providing notice, and the means for providing notice."

What we check

The statute's notice text says "employee". The firm's hiring review also asks counsel to address applicant communications. Keep the proposed notice, recipients, timing, delivery method and counsel's review in the decision record before reconsidering the hold.

Open: reviewed notice and delivery record. These review steps do not set a statutory notice deadline.

Evidence folder

The index for an auditor or a client review.

Owner: office lead

Open a record to inspect its contents. A pending file records the missing evidence; it does not stand in for a signature, a vendor answer or a completed test.

Folio Alder Bookkeeping · AI governance · 2026

AI use policypolicy/staff-policy.md

Issued

Office leadCollect staff acknowledgments.

Policy sign-offspolicy/sign-offs.md

Pending

Office leadFile signed acknowledgments after the briefing.

Tool registerregister/tool-register.md

Filed

Office leadCarry forward the inventory; record permission changes.

Hiring assessmentrisk/hiring-assessment.md

Held

Hiring leadFile test results and a new decision.

Vendor answers V-01 to V-05vendors/vendor-review.md

Open

Managing partnerReplace draft terms with signed evidence.

Review and approval recordsreviews/decision-record.md

Open

Managing partnerDocument every change and release decision.

Incident logincidents/incident-log.md

Ready

Office leadRecord issues, actions and closure evidence.

Review calendaroversight/review-calendar.md

Scheduled

Office leadHold the first quarterly review.

Restrict access to sign-offs and applicant review records. Share a redacted evidence index with a client; the managing partner approves the specific records released.

Ongoing oversight

Quarterly reviews, with an earlier review when the use changes.

Program review calendar
Review date	Owner	Work and record
January 29, 2027	Office lead	Refresh approved uses and staff acknowledgments. Hiring lead rechecks the ranking hold and open vendor gaps. Save minutes and decisions.
April 30, 2027	Managing partner	Review client-data boundaries and tax-season issues. Office lead records incidents, corrective actions and policy changes.
July 30, 2027	Hiring lead	Recheck any approved hiring use, vendor changes, human review records and applicant concerns. Record whether the use continues or stops.
October 29, 2027	Managing partner	Review the full program, evidence access and next-year ownership. Issue a revised policy when needed.

Bring the review forward

Any staff member reports a new AI feature, a change in data or purpose, an unexplained ranking, an applicant concern or a suspected disclosure to the office lead. The office lead records it the same working day and pauses the affected use when harm or exposure is possible. The managing partner assigns a reviewer before restart.

A vendor model update, changed terms, new subprocessor or change in hiring notice guidance also triggers a review. Keep the earlier configuration and the new decision together.

NIST framework mapping

The four functions in NIST AI 100-1, AI RMF 1.0.

Govern

Set ownership and operating rules.

Staff policy Review calendar

Map

Describe the hiring use and the people it affects.

Hiring assessment Illinois hiring rules

Measure

Check the evidence and test the use.

Assessment checks Vendor evidence

Manage

Record the hold, follow up and revisit decisions.

Release decision Evidence folder

This is the firm's cross-reference to the framework. It is not a NIST certification.

Sources

Sources checked October 30, 2026.

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