AI Policies That Work in the Caribbean: Turning Principles into Procedures with Dawgen TRUST™

Turning Principles into Procedures (Without Killing Innovation)

Executive Summary

Most organisations say they want “Responsible AI.” Many publish high-level principles like fairness, transparency, privacy, and accountability. But when auditors, regulators, customers, or boards ask the operational question—“Show me how you do this day to day”—the answer often breaks down.

That is the gap between policy and practice.

In the Caribbean, where teams are lean and adoption is accelerating through vendor platforms and embedded AI features, policies must be:

• practical enough to be used,

• enforceable enough to matter,

• clear enough to reduce ambiguity,

• simple enough to scale across territories,

• and structured enough to become audit evidence.

This article provides a practical blueprint for building AI policies that work, aligned to the Dawgen TRUST™ Framework. We’ll show:

• the 8 AI policy components every organisation needs,

• how to tier policy requirements by use-case impact,

• how to govern “shadow AI” and staff use of public tools,

• what to include in contracts and procurement procedures,

• how to set policy controls so they become audit-ready evidence,

• and a 30–60–90 day roadmap to implement quickly.

1) Why Most AI Policies Fail

AI policies fail for three predictable reasons:

1.1 They are too generic

They read like international guidelines—ethically inspiring but operationally vague.

1.2 They are too technical

Written by specialists, they don’t translate to what business owners and frontline teams must do.

1.3 They are not connected to controls

If policy is not linked to approval workflows, monitoring dashboards, vendor contracts, and evidence packs, it becomes shelfware.

A working AI policy is not a document. It is a system of rules + controls + evidence.

2) What “Policy” Actually Means in AI Governance

An AI policy must define:

• what is allowed,

• what is prohibited,

• who is accountable,

• how decisions are approved,

• how risks are assessed and controlled,

• how evidence is produced,

• how incidents are handled,

• how vendors are governed,

• how compliance is demonstrated.

In other words: policy is the operating manual for trust.

3) The Dawgen TRUST™ Policy Architecture

To keep AI governance scalable, Dawgen Global recommends a modular architecture rather than one giant document.

Core policy documents (recommended)

1. AI Governance Policy (the umbrella)

2. AI Use-Case Tiering Standard

3. AI Risk Assessment & Controls Standard

4. AI Data & Privacy Standard

5. AI Security Standard (including GenAI safety)

6. AI Vendor & Procurement Standard

7. AI Monitoring & Change Management Standard

8. AI Incident Response & Escalation Standard

Each can be short—but must be enforceable.

4) The 8 Essential Components of an AI Policy That Works

Component 1 — Clear Scope: “What counts as AI here?”

Define AI broadly enough to include:

• machine learning models and scoring engines,

• GenAI tools and assistants,

• embedded AI features in SaaS platforms,

• decision automation and optimisation engines,

• third-party AI outputs used to make decisions.

Why it matters: Many organisations miss AI exposure because they define AI too narrowly.

Component 2 — Use-Case Register and Mandatory Disclosure

Policy should require that all AI use cases be logged in an AI Register—including vendor AI and departmental AI tools.

Minimum rule:

If AI affects a process, it must be registered.

Why it matters: Visibility is the first control.

Component 3 — Tiering: “Not all AI needs the same governance”

Policy should define tiers and minimum requirements.

Example:

• Tier 1: high-impact decisions (people/money/compliance)

• Tier 2: material operational impact

• Tier 3: low-impact productivity

Why it matters: Tiering makes governance practical and proportional.

Component 4 — Accountability: Define who owns outcomes

Policies should include a simple RACI model:

• Business Owner: accountable for outcomes and customer impact

• Data/IT Owner: accountable for system integrity and access controls

• Risk/Compliance Owner: accountable for defensibility and assurance

• Internal Audit (where applicable): independent assurance

Why it matters: AI becomes unsafe when ownership is vague.

Component 5 — Controls: Translate principles into minimum control requirements

For each tier, define control requirements across Dawgen TRUST™:

• decision logs and traceability

• human-in-the-loop thresholds and overrides

• data quality and privacy controls

• security controls (access, logging, GenAI boundaries)

• vendor contract clauses and due diligence

• monitoring dashboards and drift thresholds

• validation/testing cadence

• customer/employee recourse processes (Tier 1)

Why it matters: principles without controls are not governance.

Component 6 — Vendor AI and Procurement Rules

Policy should require:

• vendor AI disclosure (AI features, subprocessors, data use)

• audit rights and change notification clauses

• incident reporting timelines

• data retention restrictions and training-use restrictions

• exit and portability requirements for Tier 1 vendors

Why it matters: most Caribbean AI adoption is vendor-led.

Component 7 — Staff Use of AI Tools: Shadow AI controls

Every AI policy must address:

• what staff can and cannot paste into public AI tools,

• approved tools list,

• safe prompt guidance,

• requirements for checking AI output accuracy,

• restrictions on using AI for high-impact decisions without approval.

Why it matters: shadow AI is the fastest-growing AI risk.

Component 8 — Evidence and Audit Readiness

Policies must require the creation of evidence packs for Tier 1 systems, including:

• risk assessment and controls mapping

• testing results

• monitoring dashboards

• change logs

• vendor documentation and contract controls

• incident logs and remediation records

Why it matters: Evidence is what turns policy into defensibility.

5) Make Policies Stick: Connect Them to Workflows

A policy that is not connected to workflows will be ignored.

Dawgen Global recommends embedding policy enforcement into:

• procurement approvals,

• IT security reviews,

• project intake and architecture review,

• compliance sign-offs,

• internal audit planning,

• vendor contract templates,

• go-live checklists,

• monitoring dashboards.

Policy becomes real when it blocks unsafe action—and enables safe action.

6) The “Policy Pack” for the Caribbean (Lean but Strong)

Because Caribbean organisations often have lean risk and IT teams, the policy pack must be operationally efficient.

A best practice approach is:

• one short umbrella AI Governance Policy (6–10 pages),

• 3–5 one-page standards/checklists that teams actually use,

• standard templates: AI register entry, risk assessment form, evidence pack checklist.

This keeps adoption high and friction low.

7) 30–60–90 Day Roadmap to Implement AI Policies Fast

First 30 days: Draft + define scope + tiering

• define “AI” and scope

• build AI register template

• define tiering criteria and minimum controls

• publish staff “safe use” rules

Days 31–60: Embed into workflows

• integrate into procurement and project approvals

• define required evidence pack templates

• publish vendor AI contract addenda

• launch training for key teams

Days 61–90: Operationalise monitoring and assurance

• implement Tier 1 monitoring cadence

• run incident tabletop exercise

• perform first Tier 1 assurance review

• refine policy based on early feedback

Moving Forward: The Dawgen Global Advantage

Dawgen Global helps Caribbean organisations implement AI policies that are:

• practical and usable,

• audit-ready by design,

• aligned to global trust expectations,

• scalable for multi-territory operations,

• and built to accelerate innovation safely.

Next Step: Request a Proposal

If your organisation is adopting AI and needs policies that can withstand audit scrutiny, regulator questions, partner due diligence, and reputational pressure, Dawgen Global can help.

📩 Request a proposal: [email protected]
💬 WhatsApp Global: 15557959071

Share your sector and your top AI use cases. We’ll propose an AI governance policy pack and implementation roadmap tailored to your operating model.

About Dawgen Global

Dawgen Global is one of the top accounting and advisory firms in Jamaica and the Caribbean, providing multidisciplinary services in audit, tax, advisory, risk assurance, cybersecurity, and digital transformation. Through our borderless, high-quality delivery methodology, we help organisations implement AI responsibly—embedding governance, controls, and audit-ready assurance that builds trust and protects long-term value.