# The government just told CISOs to govern their AI's data

> Canonical: https://roblinton.com/writing/asd-ai-guidance-govern-the-data/
> Author: Rob Linton · Published 2026-09-07

**TL;DR:** In May 2026 ASD's ACSC, with its Canadian, NZ and UK counterparts, told security leaders to adopt AI for cyber defence and to govern the data they give it. The second instruction is the one that matters: least-privilege access for AI, enforced policies on what AI tools may read, auditable AI-assisted actions, and a vendor question list that asks exactly where your data goes. That checklist is now the procurement script for every security-mature buyer in the country.

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In May 2026 the Australian Government told every CISO in the country two things at once:
use AI in your cyber defence, and govern the data you give it. The publication is
"Opportunities for AI in cyber defence", from ASD's Australian Cyber Security Centre,
co-sealed by the national cyber centres of Canada, New Zealand and the United Kingdom.
Most of the commentary focused on the first instruction. The second one is the story.

I have spent thirty years on [one question](/writing/thirty-years-one-problem/): who is
allowed to read this? This paper is the first time I have watched four governments ask it
about AI, in writing, for the exact audience that signs the purchase orders.

## What does the ASD guidance actually say?

Adopt AI, carefully, with the emphasis on carefully. The 23-page paper maps AI onto the
six functions of the Information Security Manual (Govern, Identify, Protect, Detect,
Respond, Recover), then spends its strongest sections on what has to be true of the data
underneath.

The lines worth reading twice, quoted exactly:

- Organisations should be "enforcing least privilege access, restricting data exposure to
  AI systems" and "maintaining auditability of AI-assisted actions" (p. 7).
- They should "define and enforce policies governing what data AI tools may access, how
  data may be used and where outputs may be transmitted" (p. 15).
- Integrations should "use controlled and auditable integration methods, such as
  purpose-built security platforms or secured API integrations" (p. 14).
- And the framing that holds it together: "Data readiness is a core prerequisite for AI
  adoption."

Least privilege is thirty-year-old language (every one of those sentences would sit
comfortably in a mainframe security manual). What is new is who it applies to: the paper
points them at AI tools, including agentic AI, which it says needs bounded autonomy,
sandboxing, traceable actions and human approval for anything high-impact. An agent is a
user now, and the government just said so.

## Why is Appendix A the part worth printing?

Because it is a procurement script, and your next AI vendor will be marked against it.
Appendix A is a question list for AI vendors: measurable outcomes, scope and limits,
human oversight, transparency, and a block on data protection that includes this one,
quoted exactly: "Which jurisdictions process or store customer data, including through
third-party AI services?" (p. 19).

Read that question the way a vendor will have to answer it. Most AI products route data
through a frontier-model API, which routes it through whatever infrastructure sits behind
that. Answering the jurisdiction question honestly, for every hop, is going to be an
uncomfortable exercise for a lot of sales teams. My read: within a year, fluency in
Appendix A will separate the AI vendors who sell to government and defence from the ones
who do not.

The economics point the same way. I have written before about
[the repatriation pattern](/writing/cloud-repatriation-ai-parallel/): enterprises pulling
steady-state workloads back onto infrastructure they control, and the same turn now
starting in AI. This paper adds the compliance half of that argument. Cost pushes the
workload home; now the government's own question list asks where home is.

## What would I actually do with this?

I work on products at Senetas that live in exactly this territory, so read my enthusiasm
with that in mind (the opinions here are mine, not the company's). The design principle I
keep coming back to is the one the paper circles without naming: an AI agent should see
only what the person behind it is cleared to see. No separate, softer rulebook for
machines; the same rules, enforced at the data, with an audit trail you can actually point
at afterwards.

For a CISO, the paper converts to a short list:

1. **Inventory what your AI tools can currently read.** Not what they are supposed to
   read. What they can reach. This number is usually a surprise.
2. **Run Appendix A against your existing AI estate**, not just new purchases. The
   retrofit findings are where the risk is.
3. **Treat agents as users.** Least privilege, scoped credentials, an audit trail. The
   paper says this plainly; most current deployments do not do it.
4. **Ask the jurisdiction question of every vendor, every hop.** If the answer takes more
   than a paragraph, that is the answer.

## The honest caveat

Guidance is not regulation. Nothing in this paper compels anyone, and ASD does not
endorse vendors or products, mine included. It is also fair to note the paper spends most
of its pages on the opportunities, not the governance; I am quoting its spine, not its
word count. And I am not a neutral reader. The reason I find this paper persuasive is
that I spent years building for the position it takes, which is either corroboration or
confirmation bias, and a sceptic should hold both hypotheses.

But the direction is hard to argue with. Four allied governments have now put in writing,
for the people who own security budgets, that AI adoption starts with deciding what the
AI is allowed to read. Rob Linton has been asking that question since the nineties; it is
pleasant to have company.

Net: data readiness first, AI second. Print Appendix A and take it to your next vendor
meeting ([the annotated walkthrough](/asd-appendix-a-annotated/) is on this site).