Separate the Model, Agent, Operator, and Decision

Begin with a system boundary

A company licenses a model, connects it to internal records, and uses an assistant to draft recommendations. Several parties contribute technology, but that does not mean they all make the same decision or occupy the same legal role. Draw the deployed workflow before assigning labels.

The NIST Map playbook is a reference for recognizing system context. The distinctions below are explanatory aids; legal definitions must come from the relevant law or other source.

Four different questions

Layer	Description to establish	Why it changes the review
Model	The underlying component and its limits	It does not describe every downstream use
Agent workflow	Tools, data, instructions, and permissions	It identifies what the deployed system can actually do
Operator	The organization configuring and running the workflow	It helps locate responsibility for factual answers
Decision	The action or recommendation affecting someone	It identifies the activity whose rules need checking

Do not automatically transfer a role label from a supplier’s product page to the organization using the workflow. The relevant definition may depend on the activity and source.

Worked boundary example

If an assistant only drafts a customer reply, record who approves and sends it. If a later version sends the reply or changes an account automatically, update the boundary and decision authority. The model may be unchanged while the legally significant fact pattern changes.

This also explains why a source can be relevant without every obligation in it applying. A provision may address a particular entity or decision rather than every system that contains AI.

Record context alongside the conclusion

Store the profile version, affected locations, role assumptions, source version, and unresolved definitions with the review. If a conclusion changes, a later reader should be able to see whether the cause was a new source, a new fact, or a different interpretation.

Carver can help organize potential provisions and open questions. It does not turn a technical diagram into a legal opinion. Route material role and applicability questions to a qualified reviewer before relying on them.