At a housing association, the managing director asks the management team who actually maintains the AI register. There is a pause, and then everyone looks at the data protection officer (DPO). She says she is happy to review the register, but she has no way of knowing which tools the lettings department started using this month.
She is right on both counts. The AI register is the organisation's responsibility, and final responsibility rests with the board. Below that level it only works in layers: one owner of the register as a whole, an owner for each row in the business, IT for observing use, procurement for the contracts and the DPO as adviser and reviewer. What belongs in the register is covered in our guide to the AI register. This piece is about who is responsible for which part.
Why does the law not name anyone?
Because no law prescribes an AI register in a fixed form, no law says who should keep one. The GDPR places accountability on the controller, which is the organisation. Article 4 of the AI Act is addressed to providers and deployers, which again means the employer as a whole, not a department. What the AI Act does require is covered in our article on whether an AI register is mandatory.
So the division of roles has to come from within: what is used, what for, under which contract and whether that is acceptable are four kinds of knowledge held by four kinds of people.
Why is "the DPO will handle it" not an answer?
It sounds sensible, but it fails for two reasons.
The first is legal. Article 39 of the GDPR gives the data protection officer an advisory and monitoring task, and Article 38 requires that they can carry it out independently, without instructions about the outcome and without duties that create a conflict of interest. Making the DPO the owner of the register would mean asking them to monitor their own work. The same argument applies to AI literacy; it is set out in our article on who is responsible for AI literacy.
The second is practical, and it is the point the DPO at the housing association made. She cannot see which tools the lettings team opens. A register held by one person describes what that person knows, and within a quarter that is no longer enough. Nor does every organisation have a DPO; whether you need one depends on what kind of organisation you are and what you process.
Who does what?
| Role | Task in the register | What goes missing without this role |
|---|---|---|
| Board or executive team | Appoints the owner, adopts the policy, bears final responsibility | Nobody to settle it when two departments want different things |
| Owner of the register (CISO, privacy or compliance team) | The format, the fields, the review rhythm, the link to the record of processing | A register that each department fills in differently and that is complete nowhere |
| Owner per row (the business) | Purpose, data, how the tool is used and the review of their own row | Rows that stay exactly as they were recorded a year ago |
| IT or the administrator | Observing which tools are opened. Sets a new tool to "No decision yet" and shows people the decision while they work | A register that only knows what someone reported |
| Procurement or contract management | Account type, data processing agreement, terms and changes to them | A tool marked as allowed although the business licence was never signed |
| Data protection officer | Advises on assessments, checks that the register matches the processing, flags what is missing | Nobody independent to say a decision is wrong |
Two rows deserve a comment. The row owner is the field most often left blank, because "IT" or "the CISO" is easier to write down. But only the department that uses the tool can say what it is used for and with which data, the two fields where the risk lies. A transcription tool for internal meetings and the same tool for conversations with tenants are two rows with two owners.
The IT row is the flip side. IT decides nothing about a tool, but it is the only function that can see the tool exists. A newly observed tool is set to "No decision yet", and that is where IT's task ends. How this division works at review time is covered in our article on keeping an AI register up to date.
Who makes the decision on each tool?
The organisation. The decision is one of four statuses: allowed, limited use, no decision yet, not allowed. The row owner makes a proposal based on purpose and data. Procurement supplies the account type and the contract. The DPO advises. The owner of the register records the decision, with a date and a name. For a tool that makes decisions about tenants or employees, the board itself signs off.
What never makes the decision: a risk score, a vendor or a tool. A score is advice. Every tool starts with the status "No decision yet" and keeps it until a named person changes it.
What does that look like at the housing association?
The management team divides the roles in one meeting. The CISO becomes owner of the register as a whole. Every quarter, IT delivers a list of the AI services that were opened, as counts, without names. For each tool, procurement supplies the account type and whether a data processing agreement is in place. Every six months, the DPO checks whether the register still matches the record of processing.
IT's first list shows why this was needed. Copilot is allowed and in the register. Alongside it, Perplexity, ChatGPT and a transcription tool turn out to be in use, and two of them appear nowhere in the register. That is not an incident: nothing had been decided about those tools, so nobody broke a rule. They are set to "No decision yet", and the CISO looks for an owner in lettings and in communications. That conversation is the register doing its job.
BeeSensible supports exactly this division of roles. The extension reports only the domain of an AI tool that was opened, at most once per day per device, without a user ID or content, and matches it against a catalogue of over 1,000 assessed tools. An administrator sees which tools have no decision yet and records the decision the organisation has made; the product decides nothing itself. The AI tools page explains more about how this works.
