Human Review Gate Definitions

Procedure BUILD

Purpose

Defines mandatory human review checkpoints in the AI development lifecycle with criteria and escalation procedures.

Related Controls

NIST MP-3 OWASP LLM09

1. Purpose

Explain why human review gates exist and when they are triggered.

Human review gates are mandatory checkpoints in the AI system lifecycle where human judgment is required before proceeding to the next phase. These gates ensure that AI outputs, decisions, and deployments receive appropriate human oversight proportional to their risk.

Document Owner: [ROLE TITLE], [DEPARTMENT]

Effective Date: [DATE]

Applies To: All AI systems at [ORGANIZATION NAME] — development, testing, deployment, and production operation

2. Gate Definitions

Define each review gate with its trigger, reviewer, and pass criteria.

GatePhaseTriggerReviewerPass CriteriaMax Wait
G1: Design ReviewDesignBefore development beginsAI Program Lead + SecurityArchitecture approved, risks identified, data classification confirmed5 days
G2: Code ReviewBuildPR/MR submittedPeer Engineer + Security ChampionCode review checklist complete, all critical items pass2 days
G3: Security ReviewTestBefore staging deploymentSecurity TeamThreat model reviewed, security tests pass, no critical/high vulns5 days
G4: Pre-ProductionDeployBefore production deploymentSystem Owner + OperationsDeployment readiness checklist complete, rollback plan tested3 days
G5: Output ReviewOperateAI generates customer-facing outputContent Reviewer / Domain ExpertOutput is accurate, appropriate, and aligned with brand guidelinesReal-time
G6: Decision ReviewOperateAI recommends action with material impactAuthorized Decision-MakerRecommendation reviewed, alternatives considered, decision documentedPer SLA

3. Gate Bypass Procedure

Define when and how gates can be bypassed in emergencies.

When Bypass Is Permitted

Gate bypass is only permitted when all of the following conditions are met:

  • A production incident is in progress (Severity 1 or 2)
  • The fix is time-critical (delay causes ongoing harm)
  • The bypass is approved by the AI Program Lead or CISO
  • A compensating review is scheduled within 24 hours

Bypass Documentation

Every bypass must be documented with:

  1. Gate bypassed: [Gate ID]
  2. Reason: [Description of emergency]
  3. Approved by: [Name, Title]
  4. Compensating review deadline: [Date/time]
  5. Actual compensating review completed: [Date/time]

Bypass Limits

  • No more than 2 gate bypasses per system per quarter
  • Bypass of G1 (Design Review) is never permitted
  • All bypasses are reported to the AI Governance Committee in the next meeting

4. Escalation & Disputes

Define what happens when a gate reviewer rejects progression.

Rejection Process

When a gate reviewer rejects progression:

  1. Reviewer documents specific reasons for rejection with actionable remediation steps
  2. Development team addresses all rejection items
  3. Team resubmits for review with evidence of remediation
  4. If team disagrees with rejection, escalate to AI Program Lead within 2 business days

Escalation Path

  1. First level: AI Program Lead mediates between reviewer and team
  2. Second level: AI Governance Committee reviews and makes binding decision
  3. Documentation: All escalations and decisions are logged in the project record

Review SLA Violations

If a gate reviewer does not complete their review within the Max Wait time, the AI Program Lead may assign an alternate reviewer. Chronic SLA violations are reported to the reviewer's management.

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