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P4

Bias Testing & Monitoring Checklist

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Pre-deployment testing: 2–4 weeks per AI system; continuous monitoring: ongoing; quarterly audit: 1–2 days

GOV-04 · Bias Testing & Monitoring Checklist

Purpose

GOV-04 is the canonical Class 3 (Bias and Fairness) governance instrument for legal AI programmes. It provides systematic procedures to detect, measure, and mitigate bias in AI systems before deployment and throughout ongoing operation. Completion of this checklist mitigates the Class 3 +1 modifier in STR-03 and produces Defensibility lens evidence for the Defensible Posture Statement (DPS).

Use this checklist for every AI system in the AI Bill of Materials (AI BoM) that carries a bias monitoring requirement flag. Completed GOV-04 reviews with identified failures must generate GOV-03 Risk Register entries. Level 3 and Level 4 bias incidents escalate to the STR-07 AI Task Force.

Trigger: AI BoM entry confirmed with bias monitoring flag → initiate GOV-04. STR-03 Class 3 modifier (+1) applied when GOV-04 not completed → GOV-04 completion removes modifier.

Ecosystem hooks: STR-03 (Class 3 modifier mitigation) · GOV-03 (Risk Register entries for failures) · VEN-01 (Class 3 vendor score input) · VEN-02 (Section 4 bias testing vendor requirement) · DAT-03 (DPA required before bias test data processing) · STR-07 (Level 3/4 escalation authority) · DPS (Defensibility lens evidence)

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Metric 0 — AI BoM Pre-Check

Before initiating bias testing, confirm the following AI BoM entry fields are complete:

| Check | Required | Status |

|—|—|—|

Key Takeaways

  • GOV-04 completion mitigates the Class 3 +1 modifier applied in STR-03 when no bias testing protocol exists

  • AI BoM Metric 0 pre-check is required before initiating bias testing — confirm DPA, bias flag, and VEN-01 score

  • Agentic Tier AI systems require continuous real-time fairness monitoring with automated kill-switch triggers

  • Level 3 and Level 4 bias incidents must escalate to the STR-07 AI Task Force within 4 and 2 hours respectively

  • All Level 2+ bias failures generate mandatory GOV-03 Risk Register entries

  • Bias testing applies ABA Rules 1.1/1.6/5.3, EU AI Act Articles 10–15, and NYC Local Law 144

  • Completed bias test results constitute Class 3 evidence for the DPS Defensibility lens

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Module Details

Type

Pillar

P4

Duration

Pre-deployment testing: 2–4 weeks per AI system; continuous monitoring: ongoing; quarterly audit: 1–2 days

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