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For brownfield systems, some documentation will need to be reconstructed from available artefacts. Training data that was not version-controlled may need characterisation through statistical analysis of the deployed model’s behaviour. Model architecture details that were not formally documented may need extraction from the codebase. Design decisions that were never recorded may need recovery through interviews with the development team.

The AISDP should clearly indicate where documentation has been reconstructed rather than generated contemporaneously. Transparency about the reconstruction process is more credible to a competent authority than retroactive documentation that claims to be original. Each reconstructed section should note the reconstruction date, the method used, and the sources from which the information was recovered.

A competent authority reviewing a brownfield AISDP will expect to see gaps in the historical record. What it will not accept is fabrication: documentation that purports to describe a contemporaneous process that never occurred.

Key outputs

  • Documentation reconstruction from available artefacts
  • Transparent labelling of reconstructed content (date, method, sources)
  • Credibility through honesty about historical gaps
  • All 12 modules covered where reconstruction is needed
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