Writing / Compliance

What to require of an agency AI usage record

October 27, 2026 / 2 min read

Four requirements for county IT and procurement to put into a scope of work before the request for proposals for an AI usage record is drafted.

Your staff already use AI in their work, and sooner or later a council member, an auditor or a records request will ask what it was used for. A usage record is how the agency answers. These four requirements give county IT and procurement a plain place to start, written to go into a scope of work before any request for proposals is drafted.

  1. It runs on the agency’s own servers. The record, and the system that writes it, live on infrastructure the agency controls. Agency data does not travel to a vendor to be logged, stored or reviewed.
  2. The vendor holds no keys. Content is encrypted under keys the agency holds, so the vendor cannot read it. With nothing kept on the vendor’s side, there is nothing there to breach.
  3. Policy is decided before the AI action. The agency’s AI policy is applied when the request is made, not pieced together afterwards. The record shows that the decision came first: who acted, on which device, with which AI provider and model, and what the policy decided.
  4. Each record is checked as it arrives. Each captured entry is signed and hash-chained, and the agency’s own server checks each one as it arrives, so a record changed on its way to the server shows. Plan to keep it for at least three years, the record-keeping bar Colorado sets for AI deployers from January 1, 2027 (what Colorado SB 26-189 asks you to keep).

Written into the requirements early, these four points shape every proposal that comes back.

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See Verillian on a real device.

The Verillian console home for the last 30 days: 10 devices, 684 requests, 613 allowed and 71 denied, the Enforce, Audit and Contain cards with the two active holds, and the latest refused requests.The Verillian console home for the last 30 days: 10 devices, 684 requests, 613 allowed and 71 denied, the Enforce card with two suggested policies waiting, and the top of the Audit card.