AI Law Framework

AI due diligence

AI due diligence: what to ask a vendor

Before a firm lets an AI tool near client information, it should check how the tool handles that information. These are the questions the framework asks, with what law societies and regulators have published on the same topics.

Quotes last checked on their source pages on 3 November 2026.

How to read this page

Each group below opens to show its questions. A question is the framework’s own wording. Under it are short quotes from the bodies that publish guidance, each with the issuer, the title, the date and a link to the page it came from.

A quote shows what that body wrote. It is not our summary of its view, and it does not say what answer passes. Some questions have no quote because none of the sources we checked speaks to them directly.

Permitted use and the firm’s duties

Where the requirements come from, and whether client information may be used at all.

The 2 questions in this groupShow the questions

Where the requirements come from

Record the actual sources driving the assessment; requirements can come from several places.

What the sources say

Authority and permitted use

Confirm disclosure and use are authorised for the stated tasks. Consent, privilege and professional obligations are separate matters to assess.

What the sources say

Where the data goes

Storage, model, processing, backup, log and support locations, and cross-border transfers.

The 8 questions in this groupShow the questions

Primary storage location

Where files, prompts, outputs and indexes are stored at rest.

What the sources say

Model inference location

Where model computation takes place. Check routing settings and the exact model.

What the sources say

Other processing location

Include OCR, extraction, indexing, CPU processing and coordination outside model inference.

What the sources say

Fallback and disaster recovery location

Check overflow, failover and outage behaviour as well as the normal route.

None of the sources checked speaks to this question directly.

Logs and safety-monitoring location

Include logs containing prompts, outputs or derived sensitive information.

None of the sources checked speaks to this question directly.

Backups and replicas location

Confirm replicas, backups and recovery copies, not only the primary database.

None of the sources checked speaks to this question directly.

Support and staff-access location

Location of remote access matters even where the file stays in its primary region.

None of the sources checked speaks to this question directly.

Cross-border processing basis

Evaluate the actual transfer obligations for the jurisdictions and information involved.

What the sources say

Who handles it

The model provider, subprocessors, supplier staff, connectors and web search.

The 5 questions in this groupShow the questions

Model-provider arrangement

Identify who processes content for inference and under which contract.

What the sources say

Subprocessor register

Include model hosting, OCR, search, support, analytics, identity and any other recipient of relevant information.

What the sources say

Supplier human access

Separate customer-authorised support, safety review, legal access and routine operations.

What the sources say

Connectors and external services

Every external service may have separate data handling, permissions and retention.

None of the sources checked speaks to this question directly.

Public web search

Derived search terms can reveal confidential facts even when the full document is not sent.

None of the sources checked speaks to this question directly.

How the data is used and kept

Training, feedback, retention and deletion.

The 4 questions in this groupShow the questions

Training and service improvement

Distinguish foundation-model training from customer fine-tuning, safety review and other service improvement.

What the sources say

Feedback and support submissions

Feedback and support can send a whole conversation through a separate route.

None of the sources checked speaks to this question directly.

Retention and zero-retention scope

Review each data category, feature and model. No-training is not no-retention.

What the sources say

Deletion and legal holds

Confirm deletion from live systems, indexes, backups and subprocessors, including exceptions.

What the sources say

Security, assurance and incidents

Access control, encryption, certification scope and incident handling.

The 4 questions in this groupShow the questions

Identity and matter access

Check permissions, tenant separation, least privilege, MFA, offboarding and connected sources.

What the sources say

Encryption and key control

Check transport, storage, keys and feature exceptions. Encryption does not answer lawful-access or output-quality questions.

What the sources say

Security assurance scope

A certificate must cover the entity, service, feature and period being assessed.

What the sources say

Incidents and continuity

Confirm notification, cooperation, records, escalation and usable fallback.

What the sources say

Contract, change and exit

The contract terms, changes to the service, and leaving.

The 3 questions in this groupShow the questions

Contract and processing terms

Check the actual contracting entity and accepted terms for the selected plan and model route.

What the sources say

Model and supplier changes

Changes in models, features, terms, regions or recipients can require a fresh review.

None of the sources checked speaks to this question directly.

Exit and export

Preserve required matter records and evidence before account closure or migration.

What the sources say

Agent actions and human review

What an agent may do on its own, and who checks the work.

The 2 questions in this groupShow the questions

Agent actions and approval

Distinguish reading information from sending, filing, editing or deleting it.

None of the sources checked speaks to this question directly.

Competent human review and fallback

A named reviewer needs relevant competence, access to original sources, time to check and a usable escalation or manual route.

What the sources say

The sources

Using the questions

In the software workspace, a guided set of the same questions records what a vendor says, and a request PDF puts the questions to the vendor. Both show who has written about each question. Start from the software catalogue.

Nothing here is legal advice, and nothing approves a tool. The method page sets out what the framework does not decide.