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AAT-20.8: Biometric Categorization

AAT 5 — Medium Protect

Mechanisms exist to prohibit the sale, deployment and/or use of Artificial Intelligence (AI) and Autonomous Technologies (AAT) that categorize an individual based on their biometric data to deduce, or infer, the individual's: (1) Race; (2) Political opinions; (3) Trade union membership; (4) Religious or philosophical beliefs; (5) Sex life or sexual orientation; and/or (6) Age.

Renumbered: Formerly AAT-19.8 in SCF 2025.4.

Control Question: Does the organization prohibit the sale, deployment and/or use of Artificial Intelligence (AI) and Autonomous Technologies (AAT) that categorize an individual based on their biometric data to deduce, or infer, the individual's: (1) Race; (2) Political opinions; (3) Trade union membership; (4) Religious or philosophical beliefs; (5) Sex life or sexual orientation; and/or (6) Age?

General (1)
Framework Mapping Values
NIST AI 600-1 MS-2.10-001
US (1)
Framework Mapping Values
USA Texas TRAIGA 2025 552.054(b)
EMEA (1)
Framework Mapping Values
EMEA EU AI Act Article 5.1(g)

Capability Maturity Model

Level 0 — Not Performed

Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.

Level 1 — Performed Informally

Artificial Intelligence and Autonomous Technology (AAT) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include: ▪ Policies, standards & procedures associated with AAT domain capabilities provide limited coverage due to the depth and breadth of the existing documentation. ▪ AAT-related processes are expected to follow the organization's existing processes (e.g., incident response, asset management, change control and risk assessments). ▪ No formal Governance, Risk & Compliance (GRC) team exists to provide AAT oversight, where the Chief Information Officer (CIO), or similar function, governs technology decisions what is acceptable for AAT within the organization.

Level 2 — Planned & Tracked

Artificial Intelligence and Autonomous Technology (AAT) capabilities are requirements-driven, but are not standardized across the entity (e.g., local/regional level consistency). Capability criteria associated with this control reasonably expect the following criteria to exist: ▪ Policies and standards associated with AAT domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with AAT domain capabilities are documented and maintained by process owners. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with AAT domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Artificial Intelligence (AI)-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Asset management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.

Level 3 — Well Defined

Artificial Intelligence and Autonomous Technology (AAT) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist: ▪ Policies and standards associated with AAT domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function. ▪ Standardized Operating Procedures (SOP) associated with AAT domain capabilities are well-documented and kept current by process owners. ▪ An Artificial Intelligence Governance (AIG) team, or similar function, is appropriately staffed and supported to implement and maintain AAT domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of AI governance, risk management and compliance operations (e.g., dedicated AI governance platform). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with AAT domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls). ▪ An implemented and operational capability exists to prohibit the sale, deployment and/or use of AAT that categorize an individual based on their biometric data to deduce, or infer, the individual's: (1) Race; (2) Political opinions; (3) Trade union membership; (4) Religious or philosophical beliefs; (5) Sex life or sexual orientation; and/or (6) Age.

Level 4 — Quantitatively Controlled

Utilize SCR-CMM Level 3 criteria definitions: ▪ There are no defined Level 4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to operationalize this control. ▪ While it may be possible to develop “metrics-driven” capabilities for this control, the criteria would be organization-specific to define.

Level 5 — Continuously Improving

Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions: ▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control. ▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies. ▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.

Assessment Objectives

  1. AAT-20.8_A01 the organization prohibits the sale, deployment and/or use of Artificial Intelligence (AI) and Autonomous Technologies (AAT) that categorize an individual based on their biometric data to deduce, or infer, the individual's race.
  2. AAT-20.8_A02 the organization prohibits the sale, deployment and/or use of Artificial Intelligence (AI) and Autonomous Technologies (AAT) that categorize an individual based on their biometric data to deduce, or infer, the individual's political opinions.
  3. AAT-20.8_A03 the organization prohibits the sale, deployment and/or use of Artificial Intelligence (AI) and Autonomous Technologies (AAT) that categorize an individual based on their biometric data to deduce, or infer, the individual's trade union membership.
  4. AAT-20.8_A04 the organization prohibits the sale, deployment and/or use of Artificial Intelligence (AI) and Autonomous Technologies (AAT) that categorize an individual based on their biometric data to deduce, or infer, the individual's religious or philosophical beliefs.
  5. AAT-20.8_A05 the organization prohibits the sale, deployment and/or use of Artificial Intelligence (AI) and Autonomous Technologies (AAT) that categorize an individual based on their biometric data to deduce, or infer, the individual's sex life or sexual orientation.
  6. AAT-20.8_A06 the organization prohibits the sale, deployment and/or use of Artificial Intelligence (AI) and Autonomous Technologies (AAT) that categorize an individual based on their biometric data to deduce, or infer, the individual's age.

Technology Recommendations

Micro/Small

  • Policy prohibiting biometric categorization AI tools

Small

  • AI acceptable use policy prohibiting biometric categorization

Medium

  • Formal prohibition on biometric categorization AI

Large

  • AI ethics program with formal prohibition
  • Legal review for biometric technologies

Enterprise

  • Enterprise AI ethics and privacy framework
  • Regulatory compliance (EU AI Act, GDPR)
  • Technical controls

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