Defines which AI-driven automation actions require human approval before execution, who holds approval authority, how exceptions are logged, and what constitutes a human-in-the-loop control for SOC 2 audit purposes.
AI-driven automation can execute actions faster than any human reviewer — including actions that affect client environments, billing, security posture, or data integrity. Speed is the value proposition. It is also the risk. This standard defines exactly where the human review gate sits so that automation speed is preserved for low-risk actions while high-impact decisions always have a named human accountable for them.
This document closes the SOC 2 CC7.2 and CC8.1 gap identified in the AI Controls Mapping: the requirement that AI automation acting on client environments have documented human-in-the-loop controls, exception logging, and a quarterly review cadence.
Every AI-driven automation action falls into one of three tiers. Tier determines whether the action can execute automatically, requires human approval, or is blocked from AI automation entirely.
| PLATFORM / TOOL | EXAMPLE AI AUTOMATION | TIER | GATE |
|---|---|---|---|
| NinjaRMM | Endpoint isolation on ransomware detection | Tier 1 | HUMAN APPROVAL |
| NinjaRMM | Patch deployment in approved maintenance window | Tier 2 | AUTO + LOG |
| NinjaRMM | Pull device health data for dashboard | Tier 3 | AUTO |
| ConnectWise PSA | Close ticket and send client summary | Tier 1 | HUMAN APPROVAL |
| ConnectWise PSA | Re-route ticket between internal queues | Tier 2 | AUTO + LOG |
| ConnectWise PSA | Generate ticket summary for internal log | Tier 3 | AUTO |
| SentinelOne | Quarantine endpoint on Tier 1 threat | Tier 1 | HUMAN APPROVAL |
| SentinelOne | Run Deep Visibility query and log results | Tier 3 | AUTO |
| Microsoft Copilot | Draft client-facing email or report | Tier 1 | HUMAN REVIEW BEFORE SEND |
| Microsoft Copilot | Summarize meeting notes internally | Tier 3 | AUTO |
| Power Automate | Trigger IR runbook steps on client environment | Tier 1 | HUMAN APPROVAL |
| Power Automate | Route approval request to named approver | Tier 2 | AUTO + LOG |
A human gate is not a notification. It is not a summary sent after the action completes. It is a named human reviewing the proposed action and explicitly approving it before the automation executes. The following criteria define what counts as a valid human gate for SOC 2 purposes.
| CRITERION | REQUIRED | NOTES |
|---|---|---|
| Named approver identified | REQUIRED | A specific person — not a group or role — is identified as the approver before the action is queued |
| Approver sees the proposed action in full | REQUIRED | The approver must see exactly what will execute — not a summary. Scope, target, and expected outcome must be visible. |
| Explicit approve or deny action taken | REQUIRED | A button click, form submission, or logged response. Silence or inaction does not count as approval. |
| Timestamp of approval logged | REQUIRED | The timestamp of when the approver acted must be captured and retained. This is the audit trail. |
| Action does not execute until approval is logged | REQUIRED | The automation must be blocked pending approval — not post-hoc reviewable. Execution before approval is a gate failure. |
| Denial results in no action | REQUIRED | If the approver denies, the automation stops entirely. The denial must also be logged. |
| Timeout handling documented | RECOMMENDED | Define what happens if the approver does not respond. Default must be no action — not auto-approve on timeout. |
Approval authority is determined by action tier and impact scope. Actions affecting multiple clients or with irreversible consequences require a higher level of approval.
| ACTION SCOPE | MINIMUM APPROVER | ESCALATION IF UNAVAILABLE |
|---|---|---|
| Tier 1 — single client, reversible | Assigning technician's team lead | On-call senior tech |
| Tier 1 — single client, irreversible (data deletion, account disable) | Security Lead or Operations Owner | On-call Security Lead |
| Tier 1 — multiple clients or portfolio-wide | Security Lead + Operations Owner (both) | Escalate to executive on-call |
| Tier 1 — IR runbook on client environment | Security Lead | On-call Security Lead |
| Tier 2 — conditional auto action | Pre-approval via maintenance window approval or change request | Revert to Tier 1 gate if window not approved |
| Exception to this standard | Security Lead + Risk Owner | No exception without both approvers |
Every gate failure, gate bypass, and approved exception must be logged. Logging is not optional. An unlogged exception is indistinguishable from a deliberate policy violation for SOC 2 purposes. The exception log is reviewed quarterly as part of this standard's operating cadence.
| EVENT TYPE | LOG REQUIRED | FIELDS REQUIRED | RETENTION |
|---|---|---|---|
| Tier 1 action approved and executed | YES | Date, action, target, approver, timestamp, outcome | 12 months |
| Tier 1 action denied | YES | Date, action, target, approver, denial reason, outcome | 12 months |
| Gate failure — action executed without approval | YES — IMMEDIATE | Date, action, target, how bypass occurred, who detected it | 24 months |
| Approved exception to this standard | YES | Date, requestor, justification, approvers, expiry date | Duration + 12 months |
| Tier 2 conditional auto action | YES — AUTOMATED | Date, action, target, triggering condition, outcome | 6 months |
| Approver unavailable — action deferred | YES | Date, action, target, contact attempts, resolution | 12 months |
Use this form to log a gate event, a gate failure, or a request for an approved exception to this standard. All submissions are routed to the Security Lead and Risk Owner. Exceptions require dual approval and an expiry date — permanent exceptions are not permitted.
This standard and its exception log are reviewed quarterly. The review meeting must be attended by the Security Lead, Operations Owner, and Risk Owner. The output of each review is a dated record confirming the standard remains current and all open exceptions have been evaluated.
| REVIEW ITEM | ACTION |
|---|---|
| Exception log — all entries since last review | Review all entries. Confirm gate failures have been remediated. Confirm approved exceptions have not expired. |
| Gate failure count and trend | If more than two gate failures in a quarter, trigger a root cause review and update automation configuration. |
| Tier assignments — new automations added since last review | Classify any new AI automation actions into Tier 1, 2, or 3. Update the action table in Section 02. |
| Approver availability — on-call coverage confirmed | Confirm on-call rotation is current and all approvers know their responsibilities. |
| Standard version — material changes since last review | If scope has changed significantly, increment version number and redistribute. |