Who owns each AI tool and its data? A working register for Hong Kong SMEs

Record a business use, not just a subscription

A register should answer a practical question: may this particular use continue under its present conditions? Give each entry a stable ID and record the tool, company workspace or account, and business purpose. Split entries when the same product serves different departments with different data or permissions. A writing assistant for public product descriptions and the same product connected to a customer mailbox are different decisions, even if finance receives one invoice. Include free accounts, trials, browser extensions and AI features inside existing software when staff use them for company work.

Ask department leads to demonstrate their ordinary workflow, then reconcile their answers with subscription and expense records. An invoice can reveal a paid account but cannot establish what staff upload. Record an unknown as an open question with a person and due date; do not turn it into an assumed approval. Nominate a register coordinator to chase updates, while a named business owner remains accountable for each use. The person paying the bill is not automatically that owner.

A spreadsheet you can use in the next review

Start with a shared spreadsheet with controlled editing and version history. Put one use in each row and use the fields below as columns. Keep evidence in an access-controlled folder and link to it, rather than copying customer records into the register. The data field describes categories and boundaries; it is not a place for prompts, passwords or API keys. Where staff work in both languages, write the purpose and restrictions in clear English and Traditional Chinese so the people using the tool can apply the same rule.

This is a proposed operating template, not a certification checklist. Add renewal and exit details when they affect the decision.

Turn an incomplete entry into a decision

Consider a fictional Hong Kong distributor. Marketing uses an assistant for bilingual catalogue drafts based on public specifications. Customer service has separately connected an assistant to a shared mailbox. For marketing, the owner could propose continued use limited to public inputs, with a colleague checking claims and both language versions before publication. That is a proposed control, not evidence that the tool is accurate. Record who accepted the limit and when it will be checked again.

For the mailbox entry, suppose nobody can confirm whether the connection can send messages or how uploaded content is retained. Mark that use pending review and pause the connection while the administrator checks permissions and the owner resolves data questions. Staff can use the existing manual reply process meanwhile. If reinstated, the record must state the verified access boundary and who authorises any change. Do not copy the marketing approval across simply because both teams describe their activity as drafting.

Make the outcome explicit: keep within stated limits, restrict access, pause pending evidence, or retire a redundant use. Before retirement, identify work that depends on it, any records that must remain available, and the person handling export and access removal. Cancelling a subscription alone does not settle those responsibilities. A restrictive decision also needs a workable alternative; otherwise staff may recreate the same use in an unrecorded account.

Use guidance without overstating it

NIST AI RMF 1.0 is voluntary. Its Govern 1.6 addresses inventories of AI systems, and Govern 6 addresses third-party risks. These support the register approach; they do not prescribe this spreadsheet or require a Hong Kong SME to buy a register product. The source page says the framework is being revised, so the references here are explicitly to version 1.0.

The Hong Kong Government’s reply of 22 April 2026 identifies excessive permissions and data leakage as agent risks. Its restriction on installation on computers connected to government internal networks concerns government departments; it is not stated as a universal SME ban. Use that distinction when setting your own access review. A completed register records decisions and gaps; it does not by itself prove legal compliance or safe operation.

Keep the record alive before buying software

Choose the next review date according to the consequences of an error and how quickly the use changes. As a local starting proposal, review unresolved entries weekly until closed and stable approved uses quarterly; bring a review forward for a new data source, connector, permission, owner or material supplier change. The owner should confirm actual use, not simply advance a date. When staff leave or transfer, reassign the entry and check their access. After an incident, record the changed decision and its supporting evidence. These intervals are suggested working arrangements, not source requirements.

A spreadsheet is adequate while a coordinator can reliably reconcile changes and owners respond. Use an existing asset or service register instead if it can hold the same fields and reminders. Consider dedicated governance software only when missed reviews, conflicting copies or complex approval permissions create a demonstrated workload. Test a candidate system with your real register: can it assign owners, preserve decisions, restrict sensitive evidence and export usable records? Automated discovery may help find accounts, but it cannot explain the business purpose on the owner’s behalf.

For the next management meeting, ask every department for its current uses and nominate the coordinator. Complete one entry together, assign every unresolved question, and agree which uses may continue while checks are outstanding. If a connected assistant’s boundaries are unclear, the existing guide below helps distinguish answering from acting. Technical integration support is relevant when permissions or human handoffs must change; the initial inventory can still begin in a spreadsheet.