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From AI Policy to AI Control: Building Governance That Works

By Kathryn Rattigan on August 20, 2026
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AI governance is often treated as a policy problem: define approved uses, create an oversight framework, publish acceptable use rules, and document compliance. These steps matter, especially as increasingly more regulations are introduced that raise expectations for accountability, transparency, data governance, and lifecycle risk management. However, the harder question for many organizations is no longer whether they have AI rules in place, but whether those rules can keep pace with how AI is being adopted across the business. Public AI tools, embedded platform features, developer copilots, automated workflows, and AI agents are often introduced faster than security, legal, compliance, and risk teams can map what they access, what they influence, and what new exposures they create.

This is why AI governance must become operational. AI risk does not sit neatly inside a single model or use case. It changes depending on the data the system can reach, the identities and permissions it inherits, the applications it connects to, and the business processes it can affect. A tool that appears low risk in one context can become much more sensitive when it is connected to confidential information, privileged accounts, payment approvals, procurement workflows, or critical infrastructure. As AI agents begin acting across enterprise environments, organizations are no longer managing only human users, devices, and applications. They are also managing non-human actors that can retrieve information, make decisions, and initiate actions at machine speed.

The organizations best positioned for responsible AI adoption will be those that treat governance as a living operating model, not a static compliance document. That means identifying AI capabilities across the enterprise, classifying them by business risk, reviewing their access rights, limiting unnecessary permissions, monitoring how they interact with systems and data, and adjusting controls as use cases evolve. Regulation may define the destination, but operational governance builds the road. The objective is not to put the brakes on AI adoption; it is to give organizations the visibility, control, and confidence to innovate safely as AI becomes part of everyday work. The real test of AI governance will be whether organizations can move from written rules to practical controls that support innovation while keeping risk within clear, defensible boundaries.

Tags: AI
Photo of Kathryn Rattigan Kathryn Rattigan

Kathryn Rattigan is a member of the Business Litigation Group and the Data Privacy+ Cybersecurity Team. She concentrates her practice on privacy and security compliance under both state and federal regulations and advising clients on website and mobile app privacy and security…

Kathryn Rattigan is a member of the Business Litigation Group and the Data Privacy+ Cybersecurity Team. She concentrates her practice on privacy and security compliance under both state and federal regulations and advising clients on website and mobile app privacy and security compliance. Kathryn helps clients review, revise and implement necessary policies and procedures under the Health Insurance Portability and Accountability Act (HIPAA). She also provides clients with the information needed to effectively and efficiently handle potential and confirmed data breaches while providing insight into federal regulations and requirements for notification and an assessment under state breach notification laws. Prior to joining the firm, Kathryn was an associate at Nixon Peabody. She earned her J.D., cum laude, from Roger Williams University School of Law and her B.A., magna cum laude, from Stonehill College. She is admitted to practice law in Massachusetts and Rhode Island. Read her full rc.com bio here.

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  • Posted in:
    Privacy and Cybersecurity
  • Blog:
    Data Privacy + Cybersecurity Insider
  • Organization:
    Robinson & Cole LLP
  • Article: View Original Source

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