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A GenAI Control Framework for a Dutch Government Body

A GenAI Control Framework for a Dutch Government Body

Situation

The Client saw a major opportunity to use GenAI to raise the quality of work, increase efficiency, and create more impact, while reducing a growing operational backlog and protecting service levels. GenAI was clearly needed to move forward, and several pilots were launched across the organization.

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These pilots demonstrated real potential, but none of them made it into production. What was missing was not technical capability, but a clear path from experiment to deployment. The organization lacked a structured way to assess risks, define controls, and make confident go-live decisions, creating a clear need for support. The Client asked Nemko Digital to bring one priority GenAI use case into production while building a solid, reusable foundation for future GenAI initiatives.

Challenges

01.
Layer_1
No shared risk perspective

No shared view of which GenAI risks were relevant, their severity, or which controls would be sufficient.

02.
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Regulatory ambiguity

Legal and regulatory obligations not translated into clear operational requirements.

03.
Fragmented-ownership
Fragmented ownership

Fragmented ownership and unclear responsibilities across teams.

04.
Decision-paralysis
Decision paralysis

Long internal debates focused on interpretation rather than decisions.

05.
Stalled-go-live-decisions
Stalled go-live decisions

Uncertainty around acceptable risk levels stalled go-live decisions.

Our Approach & Solution

Nemko Digital addressed this by designing a use-case-specific GenAI governance and control framework that was both practical and scalable. We started with a detailed analysis of the use case and its context, followed by a structured GenAI risk assessment. Building on a comprehensive AI Risk Atlas, we identified, assessed, and prioritized risks based on their likelihood and impact, and determined the remaining net risk.

For each risk, we defined and mapped appropriate controls, and assessed existing controls to identify gaps. Working closely with internal experts, we created a concrete and transparent overview of more than 40 GenAI risks with remaining net risk for this specific use case, supported by a broader control landscape of over 150 possible controls. Roughly one third of the identified risks were classified as significant, requiring action before production. For these risks, 39 concrete control updates and new controls were defined, ranging from small procedural improvements to more substantial changes.

Additionally, the IBM Risk Atlas was adapted and embedded into an organization-specific GenAI Risk Atlas, creating a reusable asset for future GenAI initiatives.

01.
Kick-off
02.
Document analysis
03.
Risk analysis
04.
Control identification
05.
Framework completion
06.
Final report & hand-over

Key Metrics

To support the transition from experimentation to production, Nemko Digital established a structured GenAI risk and control foundation tailored to the client’s priority use case.

This work provided the clarity needed to assess remaining risks, define concrete control improvements, and enable confident go-live decisions, while creating a reusable framework to support future GenAI initiatives across the organization.

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40+

Use-case-specific GenAI risks with remaining net risk

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150+

Controls mapped across the landscape

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1/3

Of risks classified as significant

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39

New controls and updates defined

Value Delivered

01.

No shared view of which GenAI risks were relevant, their severity, or which controls would be sufficient.

02.

The organization now has a clear and repeatable approach for assessing and operationalizing GenAI use cases. Risks are transparent, responsibilities are clearly defined, and control requirements are concrete and actionable.

03.

Internal discussions shifted from abstract concerns to joint execution, enabling teams to work together to bring GenAI into practice.

04.

The framework now serves as a foundation to scale GenAI across the organization, supporting a growing portfolio of use cases while maintaining trust, quality, and regulatory readiness.

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