Tag: AI governance
AI is changing how people ask questions

The ICO has published new guidance on AI-generated FOI requests to help public authorities deal with Freedom of Information requests involving artificial intelligence.
The guidance explains that people now use AI tools to help them make information requests. As a result, some requests may look longer, more formal or more complex than before. Some may also rely on wording that does not quite fit the law.
Why this matters beyond FOI
At first, this may sound like a public sector issue.
However, private businesses should still pay attention.
If people can use AI tools to write Freedom of Information requests, they can also use them to write subject access requests, complaints, contract challenges and customer queries.
Therefore, this is not just a story about FOI.
It gives businesses a useful warning about what comes next.
People now have tools that help them ask formal questions quickly. Sometimes those questions will make sense. Sometimes they will not. Either way, businesses need to know how to respond.
Why this matters for UK businesses
Freedom of Information law applies to public authorities. Therefore, most private businesses do not need to respond to FOI requests.
However, private businesses do need to deal with data protection rights under the UK GDPR.
For example, individuals may ask for a copy of their personal data through a subject access request. Athlex has a helpful DSAR guide for SMEs that explains what these requests involve and why they can become difficult to manage.
Individuals may also ask how your business uses, shares, stores or deletes their data.
AI can make requests look more formal
Because of AI tools, those requests may now look more detailed.
They may also sound more legal than before.
That does not mean the request is correct. However, your business still needs a clear process for handling it.
In practice, your team should know:
- who deals with requests;
- how they track deadlines;
- where they can find personal data;
- when they need legal input;
- how they check whether AI tools play a role;
- how they respond clearly and fairly.
Without that structure, even a simple request can create stress.
Once stress enters the process, mistakes become more likely. Because apparently one awkward email can still ruin everyone’s afternoon.
The real risk is not the AI-generated request
AI-generated requests may feel frustrating. They may run too long. They may quote the wrong law. They may also ask for information the person cannot receive.
However, the request itself is not the main risk.
The bigger risk appears when your business cannot explain what it does with personal data.
Requests test your data protection controls
For example, a business may struggle if it cannot explain:
- what personal data it holds;
- why it holds that data;
- where teams keep it;
- who can access it;
- which suppliers process it;
- whether AI tools use it;
- how long the business keeps it;
- whether the privacy notice matches reality.
As a result, a request can quickly become more than an admin task.
It can test your data protection controls.
It can also show whether your policies match what actually happens inside the business.
If you need practical support reviewing your current position, Athlex’s GDPR consultancy services can help you assess gaps and decide what needs attention first.
AI makes transparency more important
Many businesses already use AI in everyday ways.
For example, they may use AI to:
- summarise customer emails;
- support recruitment;
- review complaints;
- analyse customer behaviour;
- support fraud checks;
- write internal notes;
- power website chatbots;
- prioritise sales leads.
Some of these uses may feel low risk.
However, personal data changes the position.
If an AI tool uses personal data, the business needs to understand what happens to that data.
That means asking clear questions.
What data does the tool use? Why does the business use it? Has the business told the person? Does a supplier help process the data? Can the supplier use the data to train the tool? Could the output affect someone?
These are not abstract legal questions.
They are practical business questions.
Increasingly, customers, staff and regulators may expect clear answers.
Automated decision-making is where AI gets serious
Some AI tools simply help teams work faster. Others go further. They may help decide who gets an interview, whether a transaction looks suspicious, what price someone is offered, or whether a customer should receive a service. At that point, AI is no longer just a helpful tool in the background. It may be influencing decisions that affect real people.
That is why automated decision-making needs special care.
The Data Use and Access Act 2025 has changed parts of the UK’s data protection rules. In simple terms, it gives organisations more flexibility to use automated systems for significant decisions. However, the ICO is clear that this flexibility depends on appropriate safeguards still being in place.
So, this is not a free pass to hand decisions to AI and walk away whistling. Where an automated decision has a legal or similarly significant effect on someone, businesses still need to think carefully about fairness, transparency and challenge. For example, people may need to be told about the decision, given a chance to challenge it, allowed to make their views known and given access to meaningful human involvement.
This matters for businesses using AI in areas such as:
* recruitment;
* fraud checks;
* lending or affordability decisions;
* customer risk scoring;
* access to services;
* pricing;
* complaints handling.
The key question is not simply:
Are we using AI?
The better question is:
Could this AI use affect someone in a meaningful way?
If the answer is yes, the business needs to slow down and check the rules before the system goes live.
That means understanding what the AI tool does, what data it uses, how decisions are made, what role humans play and how people can challenge the outcome. Because “the system recommended it” is not a data protection strategy.
It is a sentence that usually arrives shortly before someone asks for evidence. In short, AI can support better decisions. However, businesses still need to understand how those decisions are made and whether people have proper safeguards.
A human review also needs to be real. If someone simply accepts the AI output without thinking, that is not meaningful oversight. It is just automation wearing a human hat, which is less comforting than some people seem to think.
What businesses should do now
The answer is not to panic.
It is also not to ban every AI tool and pretend everyone will go back to manual spreadsheets.
Instead, businesses should take practical steps.
1. Map where AI is being used
First, find out where AI is being used across the business.
This should include obvious tools, such as chatbots and AI platforms. However, it should also include less obvious uses in HR, marketing, sales, customer service, finance and operations.
For each use, ask:
* Is personal data involved?
* What is the AI tool doing?
* Is a supplier involved?
* Is the output used to make decisions?
* Has anyone checked the data protection position?
This does not need to be complicated. However, it does need to be clear.
2. Review your privacy notices
Next, check whether your privacy notices still reflect reality. If your business uses AI in a way that affects personal data, your privacy information may need to explain this. For example, you may need to explain what data is used, why it is used, who it is shared with and what rights people have. A privacy notice should not be a dusty webpage that nobody trusts. Instead, it should be a clear explanation of what actually happens. Athlex can support businesses with practical privacy notice and compliance reviews through its data protection services.
3. Prepare for AI-assisted DSARs and complaints
Businesses should also prepare for more detailed requests and complaints. For example, people may use AI to help them ask about:
* what personal data you hold;
* how AI tools use their data;
* whether decisions are automated;
* how long information is kept;
* whether data has been shared with suppliers;
* whether they can object or challenge a decision.
In addition, AI tools may make complaints look more formal, more detailed and more legal than before. Some complaints may be valid and well explained. However, others may be based on misunderstandings, incorrect assumptions or wording copied from an AI tool without much thought behind it. As a result, your DSAR and complaint process should be easy to follow.
Your team should know what to do, who to involve and when to escalate. They should also understand how to respond clearly when a complaint is broad, unclear, abusive, repetitive or based on incorrect legal points.
That way, the business can respond properly without turning one email into a full organisational incident.
Received a data protection complaint and not sure what to do first?
Athlex has created a free Data Protection Complaints Checklist to help businesses take a calm, practical first step when a data protection complaint comes in.
The checklist helps you think through:
* what the complaint is actually about;
* whether personal data is involved;
* whether there is a potential breach;
* who needs to be involved internally;
* what evidence should be kept;
* when the issue should be escalated;
* how to avoid making the situation worse.
It is designed to help you respond clearly, quickly and with more confidence.
Ask us for your free checklist – hello@athlex.co.uk
4. Check your supplier contracts
AI suppliers can create hidden risks. Therefore, before using AI tools with personal data, businesses should check the contract position. In particular, they should understand:
* whether the supplier is a processor or controller;
* where the data is stored;
* whether the supplier uses the data to train AI models;
* which sub-processors are involved;
* what security measures apply;
* what happens if there is a breach;
* whether the supplier can support DSARs and deletion requests.
If those answers are unclear, the business may not be ready to use the tool with personal data. That may slow things down. However, it is better than discovering the issue after a complaint. If you are reviewing AI supplier terms, Athlex’s contract and clause review support can help you understand the risks before you sign.
5. Use DPIAs for higher-risk AI
Finally, businesses should complete a Data Protection Impact Assessment where AI use is likely to create higher risks. A DPIA helps identify privacy risks before a project goes live. It is especially useful where AI is used for profiling, monitoring, recruitment, fraud checks, special category data or decisions that may affect people.
A good DPIA should ask:
* Is this use of AI necessary?
* Is it fair?
* Can we explain it?
* Could it harm people?
* Are the safeguards strong enough?
* Can a human properly review the outcome?
In other words, a DPIA should not be treated as a form to complete at the end. It should help the business make better decisions from the start. Athlex provides DPIA support for businesses that need practical guidance on higher-risk processing, including AI projects.
The Athlex view: AI readiness is now part of data protection readiness
The ICO’s guidance on AI-generated FOI requests is aimed at public authorities. However, the wider message applies to many organisations. AI is changing how people ask questions. It is also changing how businesses use personal data. As a result, data protection processes need to keep up. For UK businesses, this means AI governance should not sit in a separate future project.
Instead, it should be built into everyday data protection work. That includes:
* clear records of processing;
* accurate privacy notices;
* strong supplier checks;
* practical DPIAs;
* clear DSAR processes;
* sensible human review;
* evidence of decisions;
* a clear process for handling complaints.
The businesses that manage this well will not be the ones with the longest AI strategy document. They will be the ones that can explain what they are doing, show why it is fair and respond properly when challenged. That is what builds trust. And trust is still one of the strongest data protection tools a business has. For businesses that need ongoing support, Athlex’s outsourced DPO services can help keep data protection work moving without adding pressure to already stretched teams. https://athlex.co.uk/outsourced-dpo/
Need help with AI, complaints and data protection?
Athlex helps UK businesses understand data protection in a clear and practical way. We support businesses with AI risk reviews, DPIAs, privacy notices, DSAR processes, supplier checks, complaint handling and outsourced DPO support. If your business is using AI, planning to use AI, or only just realising that your teams are already using it, now is the time to get your data protection foundations in order.
Not sure where to start with a complaint? Get our free Data Protection Complaints Checklist and get clear, practical steps for handling complaints before they escalate.
Athlex makes data protection clear, practical and built for real business decisions. Data protection made simple.
Claude Mythos and the Accountability Gap: What Happens When AI Finds the Weakness First?

What happens when AI finds the weakness before you do?
Most businesses know the basics: patch systems, manage access, check suppliers and prepare for breaches.
The problem is not awareness.
The problem is delay.
Those tasks get pushed into “next quarter”, passed between teams, half-documented or quietly left to gather dust in a folder labelled “cyber review”. Claude Mythos makes that habit harder to ignore.
Anthropic’s Claude Mythos Preview has attracted attention because of its advanced cyber capabilities. The UK AI Security Institute evaluated the model and found that it showed significant improvement on capture-the-flag challenges and multi-step cyber-attack simulations. In controlled testing, where AISI explicitly directed the model and gave it network access, the model could carry out multi-stage attacks on vulnerable networks and discover and exploit vulnerabilities autonomously. (AI Security Institute)
That sounds dramatic. It is.
But for most organisations, the key issue is not whether Claude Mythos itself will attack them.
The better question is this:
If AI can find vulnerabilities faster, can your organisation show that it manages cyber and data protection risk quickly enough?
That is the accountability gap.
Claude Mythos is not just a hacking story
The public debate around Claude Mythos has focused on cyber capability. That makes sense. “AI can help find software vulnerabilities” is a more exciting headline than “please review your supplier register”, even though the second one is probably where the real trouble starts.
AISI reported that Claude Mythos Preview achieved a 73% success rate on expert-level capture-the-flag tasks. It also became the first model to complete “The Last Ones”, a 32-step simulated corporate network attack, succeeding from start to finish in 3 out of 10 attempts and completing an average of 22 out of 32 steps across all attempts. (AI Security Institute)
Why multi-step attacks matter
Real cyber incidents rarely happen in one clean step.
Attackers often move through a chain of activity: reconnaissance, access, privilege escalation, movement across systems and exploitation.
In plain English: they do not usually knock politely on the front door. They look for a loose window, climb in, find the keys, wander around and then everyone acts surprised that the security policy did not save them.
AI systems that can help connect those steps change the risk environment.
But Claude Mythos is not only a story about what attackers might do. It is also a story about what businesses may now need to prevent, detect, document and explain.
The old basics matter more, not less
It would be easy to treat advanced AI cyber capability as something so futuristic that normal organisations cannot do anything about it.
That would be convenient.
It would also be wrong.
AISI did not test Mythos against fully defended real-world systems. Its test environments lacked protections such as active defenders and defensive tooling. AISI therefore said it could not conclude that Mythos Preview could attack well-defended systems. (AI Security Institute)
Weak security is becoming easier to expose
AISI’s practical message was still clear: Mythos Preview can exploit systems with weak security posture, and more models with similar capabilities are likely to follow. AISI highlighted basic controls including regular security updates, robust access controls, secure configuration and comprehensive logging. (AI Security Institute)
So the lesson is not “buy a panic room for your servers”.
The lesson is this:
Weak security basics are becoming easier to find, easier to test and harder to excuse.
For many organisations, the biggest risk is not a science-fiction AI attack. It is much more ordinary:
- software that nobody patched;
- excessive admin access;
- old accounts that still work;
- suppliers with unclear security obligations;
- systems nobody owns;
- logs nobody checks;
- incident plans nobody has tested;
- policies that say the right thing while reality quietly does something else.
Claude Mythos does not create all of those weaknesses.
It makes them more exposed.
The real issue: can you evidence “appropriate security”?
This is where the data protection angle matters.
The UK GDPR requires organisations to process personal data securely using appropriate technical and organisational measures. The ICO explains that this security principle requires organisations to consider risk analysis, organisational policies, and physical and technical measures. (ICO)
That does not mean perfect security. No regulator expects a small business to defend itself like a national intelligence agency, which is merciful, because most organisations are still debating who owns the shared inbox.
But it does mean organisations must match their security measures to the risk.
“Appropriate” changes as the threat changes
The word appropriate matters.
As cyber capability changes, what counts as appropriate may also change.
If AI-assisted tools make it easier to discover and exploit weaknesses, organisations may need to ask whether their current arrangements still work.
Not in theory.
In evidence.
Can you show:
- what systems hold personal data;
- who has access;
- when teams last reviewed access;
- how quickly teams apply critical patches;
- which suppliers access or host personal data;
- what contracts say about cyber incidents;
- when your breach response plan was last tested;
- how teams escalate risks;
- who makes notification decisions;
- what records you keep?
The question after a breach is not only “what happened?”
After a personal data breach, regulators, customers, insurers and business partners may ask a second question:
What did you do before it happened?
That is where many organisations get uncomfortable.
Not because they did nothing, necessarily. Often, they did some of the right things. The problem is that nobody recorded them clearly, nobody owned them properly, or nobody checked whether they still worked.
That is the accountability gap in practice.
The overlooked issue: supplier risk
One of the most under-discussed issues with Claude Mythos is not just who can use AI to find vulnerabilities.
It is who benefits first when vulnerabilities are found.
Anthropic’s Project Glasswing gives selected organisations and critical software maintainers access to Claude Mythos Preview for defensive work. Anthropic describes the initiative as a way to secure critical software and give defenders a head start, with launch partners including AWS, Apple, Cisco, CrowdStrike, Google, JPMorgan Chase, the Linux Foundation, Microsoft, NVIDIA and Palo Alto Networks. (Anthropic)
Most businesses will not get direct access to frontier AI tools
Project Glasswing may help improve widely used software. If major providers find and fix vulnerabilities earlier, many downstream users may benefit.
But most ordinary businesses will not use frontier AI security tools directly.
SMEs, charities, professional services firms and smaller regulated businesses usually depend on:
- software vendors;
- cloud providers;
- managed IT providers;
- payment platforms;
- HR systems;
- marketing platforms;
- outsourced processors;
- cyber security suppliers.
That creates a practical accountability problem.
If AI accelerates vulnerability discovery, businesses need to know whether their suppliers can respond quickly enough.
Supplier security is part of your accountability
It is no longer enough to assume “our provider deals with security”.
Organisations need to understand:
- which suppliers process or access personal data;
- whether contracts include appropriate security obligations;
- how quickly suppliers must report incidents;
- who applies updates;
- whether suppliers use sub-processors;
- what happens if a critical provider suffers a compromise;
- whether business continuity plans are realistic.
A supplier’s cyber weakness can trigger your personal data breach obligations.
That is the bit businesses need to sit with, preferably before signing another contract where the security schedule has been treated as decorative paperwork.
The defensive inequality problem
Claude Mythos also points to a wider issue: defensive inequality.
Large technology companies may use advanced AI to find and fix vulnerabilities. They have specialist teams, mature processes, direct access to frontier tools and budgets that do not immediately burst into flames when someone says “security testing”.
Smaller organisations usually do not.
They rely on vendors to fix problems, suppliers to notify them, IT providers to apply patches and internal teams to understand what all of that means for personal data.
SMEs do not need an AI cyber lab
Smaller organisations are not helpless.
But they do need good governance.
For SMEs, the priority is not building their own AI cyber lab. That would be absurdly expensive and, in most cases, about as proportionate as buying a submarine to cross a puddle.
The priority is making sure the basics are understood, documented and owned.
That means:
- keeping an up-to-date record of systems and suppliers;
- reviewing contracts with key processors;
- confirming who handles updates and patches;
- checking access controls regularly;
- maintaining breach response procedures;
- documenting key decisions;
- training staff;
- testing incident escalation.
This is where data protection governance becomes practical risk management, not just paperwork.
The dual-use dilemma
Claude Mythos also reminds us that AI cyber capability is dual-use.
The same technology that could help attackers find vulnerabilities can help defenders fix them.
Bruce Schneier, writing in The Guardian, argues that modern generative AI systems are becoming good at finding and exploiting software vulnerabilities, but defenders can also use those capabilities to identify and patch weaknesses. He points to Mozilla’s use of Mythos to find vulnerabilities in Firefox, which Mozilla then fixed. (The Guardian)
Attackers and defenders may not move at the same speed
AI may make software more secure in the long run. It could help developers spot weaknesses earlier, test systems more thoroughly and reduce the number of vulnerabilities that reach production.
But the short-term picture may be messier.
Attackers and defenders may both gain new capabilities, but not at the same speed. Some organisations will patch quickly. Others will not. Some suppliers will communicate clearly. Others will send vague emails titled “Important service update” and bury the terrifying bit in paragraph seven.
That is why governance matters.
The question is not only:
What can the AI do?
The better question is:
Who is responsible for managing the risk when AI changes the speed of the threat?
What businesses should do now
Claude Mythos should not push organisations into panic.
It should push them into action.
1. Map your systems and data
You cannot protect what you do not understand.
Organisations should know:
- what systems they use;
- what personal data they hold;
- where that data sits;
- who can access it;
- which suppliers are involved;
- which systems support critical services.
This should connect with your records of processing, supplier register, asset list and breach response process. If those things do not speak to each other, now is the time to fix that.
2. Review supplier contracts and security commitments
Supplier risk creates one of the biggest practical issues.
Businesses should check whether key contracts clearly cover:
- security standards;
- incident notification timescales;
- audit or assurance rights;
- use of sub-processors;
- patching responsibilities;
- business continuity;
- return or deletion of data;
- support with regulatory obligations.
The aim is not to turn every supplier relationship into a legal wrestling match. Tempting, but no.
The aim is to know where responsibility sits before something goes wrong.
3. Check patching and vulnerability management
If AI tools can find vulnerabilities faster, delays matter more.
Businesses should know:
- who applies updates;
- how teams prioritise critical patches;
- whether unsupported systems remain in use;
- how suppliers update managed systems;
- whether teams record patching decisions;
- who approves and reviews exceptions.
“Someone in IT probably sorts that” is not a control. It is a hope wearing a lanyard.
4. Tighten access controls
Access is one of the most common weak points.
Organisations should review:
- multi-factor authentication;
- admin privileges;
- shared accounts;
- leaver access;
- dormant users;
- supplier accounts;
- role-based permissions.
People should have the access they need, not the access they accidentally inherited during a project three reorganisations ago.
5. Test your breach response plan
A breach response plan only helps if people know how to use it.
Testing should cover:
- who identifies and escalates incidents;
- who assesses whether personal data is involved;
- who contacts suppliers;
- who decides whether the organisation must notify the ICO;
- who manages affected individual communications;
- who speaks to insurers;
- who keeps the decision log;
- who updates senior management.
A plan that nobody has tested is not a plan. It is decorative compliance.
6. Bring AI governance into the same conversation
Organisations cannot treat AI governance, cyber security and data protection as separate boxes.
If staff use AI tools to write code, review documents, analyse logs, summarise customer information, generate marketing content or automate workflows, organisations need clear rules.
That means:
- acceptable use policies;
- AI supplier due diligence;
- confidentiality controls;
- human review;
- records of AI use;
- risk assessments for higher-risk tools;
- clear accountability.
The issue is not just whether staff use AI.
It is whether anyone knows how, where, why and with what safeguards.
The Athlex view
Claude Mythos is not a reason for businesses to despair.
It is a reason to stop pretending that cyber security, data protection and AI governance are separate conversations.
They are not.
AI may change the speed at which vulnerabilities are found. It may change what attackers can do. It may also change what defenders can achieve.
But for most organisations, the immediate challenge is simpler:
Can you show that you understand your risks and have taken reasonable steps to manage them?
That is the accountability gap.
The practical lesson for ordinary businesses
Claude Mythos may be a frontier AI story, but the lesson for ordinary businesses is practical:
- know what data you hold;
- know where it sits;
- know who has access;
- know which suppliers matter;
- know how incidents are handled;
- know whether your controls actually work;
- document the decisions you make.
AI may be getting better at finding weaknesses.
Businesses need to get better at fixing them, and proving they did not ignore them.
At Athlex, we help organisations make data protection, AI governance and practical compliance easier to understand, easier to evidence and easier to maintain.
Because waiting until a vulnerability becomes a breach is not a strategy.
It is procrastination with consequences.
Need help reviewing your data protection, supplier or AI governance arrangements?
Athlex helps organisations turn complex compliance requirements into clear, practical steps.
From supplier reviews and breach readiness to AI governance and data protection documentation, we help you understand your risks before they become problems.