AI data security guidance

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On May 22, 2025, the Cybersecurity and Infrastructure Security Agency (“CISA”), which sits within the Department of Homeland Security (“DHS”) [released guidance](https://media.defense.gov/2025/May/22/2003720601/-1/-1/0/CSI_AI_DATA_SECURITY.PDF) for AI system operators regarding managing data security risks.  The associated [press release](https://www.cisa.gov/news-events/alerts/2025/05/22/new-best-practices-guide-securing-ai-data-released) explains that the guidance provides “best practices for system operators to mitigate cyber risks through the artificial intelligence lifecycle, including consideration on securing the data supply chain and protecting data against unauthorized modification by threat actors.”  CISA published the guidance in conjunction with the National Security Agency, the Federal Bureau of Investigation, and cyber agencies from Australia, the United Kingdom, and New Zealand.  This guidance is intended for organizations using AI systems in their operations, including Defense Industrial Bases, National Security Systems owners, federal agencies, and Critical Infrastructure owners and operators. This guidance builds on the [Joint Guidance on Deploying AI Systems Security](https://www.cisa.gov/news-events/alerts/2024/04/15/joint-guidance-deploying-ai-systems-securely) released by CISA and several other U.S. and foreign agencies in April 2024.

The guidance’s stated goals include raising awareness of the potential data security risks of AI systems, providing best practices for securing AI, and establishing a strong foundation for data security in AI systems.  The first part of the guidance outlines a set of cybersecurity best practices for AI systems, after which the guidance provides additional detail on three separate risk categories for AI systems (data supply chain risks, maliciously modified data, and data drift) and describes mitigation recommendations for each risk category.

The guidance outlines ten cybersecurity best practices that are specific to AI systems, and refers to the [NIST SP 800-53](https://csrc.nist.gov/pubs/sp/800/53/r5/upd1/final) “Security and Privacy Controls for Information Systems and Organizations” for additional details on general cybersecurity best practices (though does not specify any particular applicable baseline).  Several of the best practices, such as “source reliable data and track data provenance,” and “verify and maintain data integrity during storage and transport,” align with the data supply chain risks discussed in greater detail further below in the guidance.   Many of the other best practices build on security practices described in NIST SP 800-53 other common security frameworks, such as classifying data, leveraging access controls and trusted infrastructure, encrypting data, and storing and deleting data securely.  The guidance’s best practices also reference leveraging

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