Compliance officers are facing a new challenge with the emergence of ChatGPT, a powerful technology that has the potential to be a game-changer in various tasks such as translation, content writing, and coding. However, along with its benefits, ChatGPT also introduces security, compliance, and business risks that need to be addressed immediately.
One of the main challenges for compliance officers is to fully understand the risks associated with ChatGPT. These risks can come in different forms and from various directions. Internal security risks arise when employees use ChatGPT or similar applications for tasks like writing software code. On the other hand, external security risks emerge as attackers can exploit ChatGPT to write malware, create false business emails, launch convincing phishing attacks, and other similar threats.
Compliance risks also come into play when employees utilize ChatGPT in ways that may violate regulatory standards. This could lead to serious consequences for the company, including legal issues and reputational damage. Additionally, operational risks arise because despite its capabilities, ChatGPT can still make mistakes and provide inaccurate information. Strategic risks also need to be considered as companies and their competitors explore the potential opportunities that ChatGPT brings.
To effectively utilize the power of ChatGPT while minimizing risks, companies should consider assembling a cross-enterprise group to identify and address risks. This group can create a risk register, which logs all identified risks and helps in defining new risks that may arise during the process.
Implementing policies is another crucial step in combating ChatGPT risks. Companies need to develop new policies or update existing ones to reduce the identified risks. These policies should also address privacy obligations to ensure compliance with regulations concerning customer data. It is essential to document the efforts made to address the risks, providing an audit trail that can be presented to auditors, regulators, business partners, or the public upon request.
As generative artificial intelligence (AI) becomes more prevalent in the business world, it is necessary for chief information security officers (CISOs) to work with senior management and the board to govern the integration of this technology into everyday operations. Deploying governance frameworks specifically designed for AI, such as the ones published by NIST and COSO, can help CISOs and risk managers understand how to govern ChatGPT effectively.
Fortunately, there are governance, risk, and compliance (GRC) tools available to assist in implementing these frameworks. These tools enable companies to map the principles and controls of AI frameworks with existing risk-management frameworks and controls within their enterprise. By doing so, organizations can identify and implement necessary controls while maintaining an audit trail of their work.
Ultimately, senior management and the board play a critical role in deciding how to utilize ChatGPT within the enterprise. The responsibility of the CISO is to ensure the technology is used in a risk-aware manner and meets regulatory obligations.
In conclusion, compliance officers must be proactive in identifying and addressing the risks associated with ChatGPT. By understanding the risks, implementing appropriate policies, and working closely with senior management, companies can harness the power of ChatGPT while mitigating potential threats. As generative AI continues to evolve, it is crucial for organizations to adapt and embrace this technology in a responsible and compliant manner.