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Applying the minimization principle to AI governance

Effective AI governance should be based on "governance minimization," tailoring oversight and compliance requirements to the specific risks and content of each AI use.

Published

Contributors:

Daniel Alfredo Zamudio Lopez

AIGP

EPMO Director

Santander Bank North America

The conversation surrounding artificial intelligence governance is often trapped in a loop of diagnosing symptoms while leaving the operational needs uncovered. Organizations frequently make the mistake of imposing a one-size-fits-all blueprint on dynamic technologies. 

When a new AI initiative arises, the immediate response is to introduce overlapping steps and processes of uncoordinated oversight with "too many cooks in the kitchen," where multiple departments add excessive, protective parameters out of caution rather than strategic alignment. 

This friction creates a heavy workload that slows down value delivery. To bridge this gap, leadership must recognize that AI governance cannot be static. Every use case demands different requirements based on its unique nature.

This complexity is reflected in modern regulatory frameworks like the EU AI Act, which demands strict adherence to a specific risk taxonomy. That said, organizations should not assess risk in a vacuum but evaluate their precise role within the ecosystem — whether they are a "provider" developing the model or a "deployer" integrating an external tool. 

In addition, the compliance requirements for a simple corporate chatbot are completely different from autonomous agents handling sensitive operational workflows and both examples are distant from a sovereign retrieval-augmented generation architecture. Forcing these polarized scenarios through the same pipeline often paralyzes delivery, proving that governance must be as adaptable as the technology it aims to oversee. 

To break this loop, a foundational principle from the privacy world is perfect to repurpose for organizational design: "data minimization." Just as privacy engineering dictates to process only the data that is necessary for a specific purpose, organizations might benefit from a model of "governance minimization." 

Contributors:

Daniel Alfredo Zamudio Lopez

AIGP

EPMO Director

Santander Bank North America

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