AI Product Launch Compliance Pack
What blocks a launch is rarely functionality. It is five documents that do not agree with one another: a processing purpose stated in the privacy policy that the PIA never assessed, a service description in the filing that the live version has already changed. We deliver the user agreement, privacy policy, PIA, filing materials and labelling scheme as one set, with the order, the wording and the version aligned.
The difficulty is consistency, not drafting
Launch compliance is usually split into five workstreams running in parallel: legal drafts the user agreement and privacy policy, an external adviser prepares the filing materials, security writes the PIA, and product designs the labelling scheme. Five documents arrive and the set looks complete. What a regulator asks is not whether each exists but whether they agree. The same processing activity described four different ways across five documents is harder to explain than a missing file.
The pack treats the five as one system: establish the facts, draft the texts, then cross-check.
The five documents
| Document | Function | Deliverable |
|---|---|---|
| PIA report | Evidence that high-risk processing was assessed beforehand | Eight-section report, remediation list, review triggers |
| Privacy policy | Notice of processing and basis for consent | Full policy, separate-consent implementation, rights channels |
| User agreement | Service rules and allocation of liability | Body, acceptable use policy, SLA, change log |
| Filing materials | Evidence that service and algorithm meet admission requirements | Filing forms, algorithm description, self-assessment, undertakings |
| Labelling scheme | Implementation of the synthetic-content labelling duty | Interface specification, API labelling, corresponding user terms |
Who it is for
- Generative AI products preparing a first launch, particularly those serving the public;
- Products already live where document versions have diverged and regulatory questions cannot be answered;
- Companies needing a complete compliance record before financing or acquisition diligence;
- Education, medical and financial contexts involving sensitive personal information or minors.
Process and timeline
- Data-flow and functionality mapping (about one week): processing activities, model call chain, third-party sharing and retention.
- PIA and remediation (about two weeks): rating, conclusion, acceptance of high-risk remediation.
- Drafting (about two weeks): privacy policy and user agreement, each item mapped to the PIA conclusion.
- Filing materials and labelling scheme (about two weeks): consistent with the texts; labelling implemented in interface and API.
- Cross-check and delivery (about one week): consistency review across the four texts, producing the version pack.
The engagement usually runs six to eight weeks. Filing review time is additional and depends on the actual queue.
Deliverables
- Final versions of the five documents with a version pack, effective dates and approval records;
- A change log and evidence schedule that can be cited directly in inspection, financing or diligence;
- A pre-launch checklist covering ten key points;
- A downloadable compliance checklist covering five documents and thirty-two checkpoints, for internal review and printing.
Frequently asked questions
Can we do only the user agreement and the privacy policy?
Yes, but the factual basis for both comes from the PIA. Without it, the purposes, categories and third-party sharing in the policy have nothing behind them, and the same is true of the filing materials.
Is a PIA mandatory?
Any one of four situations — sensitive personal information, automated decision-making, processing on instruction or provision to third parties, and cross-border provision — triggers the statutory assessment. Few AI products avoid all four.
What happens when the product changes after the documents are done?
The change-trigger rules apply: a new purpose, a new model provider, a new module and a change of labelling each correspond to a different update and to whether consent must be re-obtained. A trigger table is delivered with the pack.
How does this relate to algorithm filing?
Filing is the admission procedure; the pack is its factual basis. The service description, algorithm explanation and security assessment in the filing should match the PIA and the privacy policy; inconsistency usually attracts a request for supplementary explanation.
Related reading
The AI product launch compliance document pack, user agreements for AI products, privacy policies for AI products, personal information protection impact assessment, data processing agreements in AI.