Service · Wolff Applied AI

AI Governance Starter

A lean governance framework for AI in mid-sized companies — oriented on the EU AI Act and GDPR.

3–5 weeksDuration
On requestInvestment
6Deliverables

Why this offer matters now

In 3–5 weeks, the starter package creates a lean, mid-market-suitable governance framework for AI use — oriented on the EU AI Act and GDPR, deliberately practical rather than overly bureaucratic. We capture actual AI use, set up an AI inventory, create a signature-ready usage policy, a role and RACI model, as well as a risk and approval logic aligned with the EU AI Act. A short awareness briefing makes the rules workable within the team.

Starting point

In many organisations, AI is already in use — often uncoordinated, via private or unapproved services ("shadow AI"); depending on the survey, around 50–75 % of employees use generative AI without formal approval. Since 2 February 2025, the obligation to ensure employees’ AI competence applies (Art. 4 EU AI Act), and further transparency obligations under Art. 50 are planned from 2 August 2026 — without a documented framework, this diligence can hardly be evidenced. Regulated clients, public procurement bodies and auditors increasingly ask for evidence. Available templates are often either too legally heavyweight or too superficial — what is needed is an applicable, maintained framework that fits mid-sized companies.

Your benefit

  • A complete, honest view of actual AI use — including previously informal "shadow AI" — in a central register.
  • A signature-ready AI usage policy with clear dos and don’ts, data classes and approval channels that employees understand in everyday practice.
  • Clear responsibility through a role and RACI model — without new full-time positions.
  • A comprehensible risk and approval logic aligned with the EU AI Act for existing and new applications.
  • Demonstrable organisational diligence towards supervisory authorities, clients and auditors.
  • An awareness briefing that makes the rules workable within the team and supports Art. 4 competence.

A good fit when …

  • AI is already in use in your organisation — including as unapproved "shadow AI" — and a robust framework is missing.
  • You are regulated or risk-averse and want to bring order to AI before it takes on a life of its own.
  • Clients, supervisory authorities or auditors are asking for evidence of your AI governance.
  • You need a practical, mid-market-suitable governance framework instead of heavyweight bureaucracy.

How we work

4 phases, 4 gates — you decide at every transition.

  1. 01

    Kickoff & stocktaking

    In a structured kickoff with IT, compliance/data protection and management, we clarify goals, scope and non-goals (explicitly not legal advice). Through short interviews and a questionnaire, we capture actual AI use — without sanctions and including "shadow AI".

    Gate — your approvalScope fixed in writing, assumptions confirmed, data collection started.
  2. 02

    AI inventory & risk logic

    We build up the AI inventory/register and populate it with the applications and data types actually in use. Each application receives a risk class (minimal/limited/high, aligned with the EU AI Act) with a documented rationale; in parallel we define the approval and review process.

    Gate — your approvalRegister initially populated, every application with a substantiated risk class, approval process aligned as a draft.
  3. 03

    Policy & role model

    We create the signature-ready AI usage policy (dos/don’ts, data classes, approval channels, labelling) and a role and RACI model with clear escalation paths. In up to two feedback rounds, we incorporate feedback until the documents are ready for approval.

    Gate — your approvalPolicy v1.0 ready for approval, RACI confirmed by management/IT/data protection, all documents consistent.
  4. 04

    Awareness & handover

    We finalise a short awareness briefing (slides + handout) and hand over the framework in a session that includes a demo of the approval process. The AI leads are briefed on maintaining the register.

    Gate — your approvalAll six deliverables accepted, disclaimer included in all external documents, responsible persons briefed.

What you receive

  • AI inventory / register (populated)

    Maintainable template and initial population of the AI applications actually in use, with data types, provider, risk class and responsible persons — as an evidence basis.

  • Signature-ready AI usage policy

    Understandable policy with principles, dos and don’ts, data classes, approval channels and labelling guidance, ready for approval by management.

  • Role & RACI model

    Responsibility matrix for AI leads, coordination, data protection, IT and departments including escalation paths — lean and without new full-time positions.

  • Risk classification scheme

    Comprehensible logic for classifying applications into minimal, limited and high risk (aligned with the EU AI Act) with criteria, examples and rationale fields.

  • Approval & review process

    Documented workflow for new AI applications (request, review, approval, registration) including a short form and triggers for a renewed review.

  • Awareness briefing package

    Slide deck and handout for a short employee briefing on rules, data classes, labelling and reporting channels.

Base package plus optional modules

The base package stands on its own. Optional modules dock on now or later — you decide how far you go.

Awareness training for the workforce

Beyond the included awareness briefing (slides and handout), we run compact live sessions for your employees and make the new rules tangible in everyday work. A complete competence programme in the sense of Art. 4 EU AI Act remains reserved for the AI Training Programme.

available now

Multi-site or subsidiary survey

We extend the stocktaking and AI inventory to further sites or subsidiaries, including additional interviews and register entries. The base package is designed for one main site; this module cleanly covers grown group or multi-site structures as well.

available now

Annual governance review

Once a year, we jointly review whether the policy, role model and register still match actual AI use and the current legal situation, and update them as needed. This keeps the governance framework alive instead of becoming outdated after rollout.

available later

Good to know & honest scope

Good to know

Prerequisites

  • Contact persons from IT, compliance/data protection and management are available for interviews and coordination.
  • Availability of 6–10 people for short interviews or the AI use questionnaire.
  • Access to existing policies, tool/contract overviews, data processing agreements and data protection documentation, where relevant.
  • Clear decision-making authority for approving the policy and role model.

Your involvement

  • Naming contact persons from IT, compliance/data protection and management.
  • Availability of 6–10 people for the AI use survey.
  • Willingness to openly name "shadow AI" — the basis for a robust inventory.
  • Timely feedback and an approval decision by management on the policy and role model.

Credit: A preceding AI Potential Analysis, AI Strategy Sprint or EU AI Act Quick Check is credited proportionally if commissioned directly.

Honest scope

  • –No legal advice: the package is organisational consulting, oriented on the EU AI Act and GDPR, and does not replace an individual legal or data-protection review.
  • –No conformity evidence, no audit and no certificate.
  • –No in-depth handling of high-risk/Annex III cases — such cases are flagged and only handled separately together with legal/data-protection counsel.

Note: not legal advice. Content with a legal dimension (e.g. EU AI Act, GDPR, ISO/IEC 42001) is professional orientation, not legal counsel.

Key facts

Target group
Regulated and risk-averse organisations (50–500 employees) as well as public administration that want to bring order to AI before it takes on a life of its own. Addresses IT, compliance, data protection and management — especially where shadow AI use has grown.
Duration
3–5 weeks
Price
On request
Credit
A preceding AI Potential Analysis, AI Strategy Sprint or EU AI Act Quick Check is credited proportionally if commissioned directly.
Recommended next step
AI Training Programme

You receive a clear, individual proposal before any engagement. Under § 19 UStG no VAT is charged; any ancillary costs (e.g. model/hosting/API fees, travel) are not included.

Next step

Ready to get concrete?

Let us clarify in a free intro call whether this offer fits your situation — honestly and without sales pressure.As a follow-up we then recommend AI Training Programme.

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