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Module SUS-06 sigil: Sustaining pillar, Strategy layer, maturity bands 1 to 3.Deterministic sigil for Module SUS-06. The Pillar geometry encodes Sustaining (Pillar 8); the top-right marker S encodes the Strategy layer; the baseline meter encodes maturity bands 1 to 3.SSUS-06

P8

L-E

SUS-06

Technology Sunsetting Plan

Formalises how legal teams retire AI and legacy tools in a defensible, low-risk way.

ModuleoperationalPer-engagementDefensibility lensAdoption lensSophistication lensImpact lens

Audience

General CounselLegal OperationsIT SecurityRisk & ComplianceData Protection OfficerProcurementAI Governance Lead

·

Typical engagement: 12–24 weeks end-to-end, depending on system criticality and data volume.

Executive Summary

SUS-06 defines a defensible, end‑to‑end methodology for retiring AI and other legal technology assets. It starts with a Metric 0 pre‑check to confirm policy coverage, AI Bill of Materials (AI BoM) registration, and absence of unresolved Class 6 Shadow AI incidents. A seven‑factor decision matrix and ROAI 4‑quadrant impact assessment determine whether a tool should be immediately retired, planned for retirement, optimised, or retained with monitoring. The module then operationalises a four‑phase sunsetting process: Assessment & Planning, Preparation & Communication, Migration & Transition, and Decommissioning & Closure. It embeds Risk Taxonomy 2026 triggers, emergency Class 6 Shadow AI retirement rules, and explicit Agentic Tier decommissioning gates for Level 4 AI tools. SUS-06 also codifies data protection, business continuity, financial, and contractual risk mitigations, and maps them to external frameworks such as GDPR, CCPA, HIPAA, SOX, FINRA, and ABA professional responsibility guidance. The module produces DPS‑grade evidence across Adoption, Sophistication, and Defensibility lenses, including AI BoM deregistration certificates, intervention logs, destruction certificates, and full audit trails. It is designed for repeatable portfolio optimisation, regulatory readiness, and professional liability protection.

1. Purpose and Scope

SUS-06 defines how the organisation retires AI and other technology assets in a controlled, auditable, and low-risk way. It applies to all legal and adjacent tools, with specific provisions for Agentic Tier (Level 4) AI systems.

Defensibility Evidence

SUS-06 produces DPS evidence across all three lenses: Adoption lens (user notifications, training records, satisfaction surveys, usage analytics — 5-year retention); Sophistication lens (decision matrix scoring, ROAI 4-quadrant impact analysis, Risk Taxonomy 2026 Class Severity Profile, alternative solution analysis — 5-year retention); and Defensibility lens (executive sign-off, AI BoM Deregistration Certificate, Agentic Tier Decommissioning Gate records, intervention logs, data destruction certificates, contract termination documentation, Class 6 STR-07 reports, legal counsel opinions, client notification records — 7-year retention). The module operates at DPS Tier 3 (Defensible), requiring evidence availability within 48 hours of any regulatory or legal inquiry.

Operational Artefacts

  • SUS-06 Decision Matrix & ROAI Calculator

    xlsx · v2026.1

    Gated

  • SUS-06 Four-Phase Sunsetting Project Plan

    docx · v2026.1

    Gated

  • SUS-06 Exit & Decommissioning Checklist

    checklist · v2026.1

    Gated

  • SUS-06 DPS Evidence Retention Tracker

    xlsx · v2026.1

    Gated

Framework Crosswalk

NIST AI Risk Management Framework

NIST

Aligns retirement risk assessment, Class 6 Shadow AI handling, and lifecycle controls with NIST AI RMF functions Govern, Map, Measure, and Manage.

EU General Data Protection Regulation (GDPR)

European Union

Maps data migration, archival, and deletion steps to GDPR principles, data subject rights, DPIA, and breach notification obligations during technology retirement.

California Consumer Privacy Act (CCPA)

State of California

Supports CCPA-aligned consumer notification, access, and deletion processes when decommissioning systems holding personal data.

HIPAA Security and Privacy Rules

U.S. Department of Health and Human Services

Provides structure for retiring systems containing PHI, including BAAs, audit trails, and secure destruction of protected health information.

ABA Model Rules of Professional Conduct

American Bar Association

Operationalises duties of competence, confidentiality, supervision, and communication when changing or retiring legal technology used in client matters.

Operational Details

Inputs

  • · Current AI Use Policy (GOV-02) and AI Governance Framework (GOV-03)
  • · AI Bill of Materials entries and STR-07 Class 6 incident records
  • · Tool performance, usage, cost, and security/compliance metrics
  • · Vendor contracts, SLAs, and roadmap information
  • · Risk Taxonomy 2026 class severity assessments
  • · Data inventories, retention schedules, and DAT-02 Data Governance Policy
  • · Business process maps and user/stakeholder lists

Outputs

  • · Metric 0 pre-check results and Class 6 Override determinations
  • · Weighted decision matrix and ROAI 4-quadrant retirement impact analysis
  • · Approved technology retirement business case and project plan
  • · Risk register with mitigation and contingency plans
  • · Communication packs for executives, users, clients, and vendors
  • · Migration runbooks, validation reports, and performance baselines
  • · Agentic Tier decommissioning records (where applicable)
  • · AI BoM Deregistration Certificate and system shutdown evidence
  • · Data archival and destruction certificates with chain of custody
  • · Post-retirement evaluation report and lessons learned log
  • · DPS Adoption, Sophistication, and Defensibility evidence bundles

Owner

General Counsel + Legal Operations + IT Security

Telemetry & Observability

Telemetry-ready

Key Takeaways

  • Standardise Metric 0 pre-checks before any technology retirement decision.

  • Use a weighted seven-criteria matrix plus ROAI quadrants to decide retire vs optimise.

  • Trigger emergency Class 6 Shadow AI retirement when ungoverned AI use is detected.

  • Run the four-phase sunsetting process to minimise disruption and protect clients.

  • Apply Agentic Tier decommissioning gates for Level 4 AI tools before shutdown.

  • Embed data protection, business continuity, and contractual risk mitigations.

  • Retain DPS-grade evidence for 5–7 years to support defensibility and audits.

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Module Details

Type

Pillar

P8

Layer

E · Execution

Duration

Typical engagement: 12–24 weeks end-to-end, depending on system criticality and data volume.

Advisory

Yes

Access

Member access

Maturity Bands

FoundationalOperationalIntegratedOptimisedDefensible

Risk Classes Mitigated

Related Resources

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Governance

Methodology
v2026.1

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