Data Governance Readiness
How well does the nation control, classify, and protect its data — and is that data infrastructure ready to feed AI systems responsibly?
Guidance
Establish a Tribal Data Sovereignty Policy
Define what data belongs to the nation, who can access it, and under what conditions. Reference the OCAP® principles (Ownership, Control, Access, Possession) developed by First Nations. This must precede any AI vendor engagement.
Policy First
Audit & Classify Your Data Assets
Inventory data held in tribal systems, federal agencies (BIA, IHS), and third-party vendors. Classify by sensitivity: sacred/ceremonial, personally identifiable, administrative, and public. AI can only be governed if you know what you have.
Action Item
Data Repatriation Planning
Work to reclaim tribal data currently held by federal or state agencies. The Indigenous Data Sovereignty principles support nations asserting rights over data collected from their communities. Partner with NCAI or Native Nations Institute for templates.
Partnership
Sovereignty Considerations
Does the AI strategy reinforce or undermine inherent tribal sovereignty? Legal, cultural, and jurisdictional dimensions must be evaluated together.
Guidance
Maintain Jurisdictional Authority Over AI Decisions
Any AI system that makes or informs decisions affecting tribal members, land, or resources must remain subject to tribal law — not the vendor's terms of service. Include explicit jurisdiction clauses in all contracts.
Sovereignty
Require FPIC 2.0 Before Deployment
Free, Prior, and Informed Consent should extend to AI systems that affect community members. Engage elders, language speakers, and youth councils — not just elected officials — before any AI is deployed in health, education, or social services.
Community Process
Prohibit Use of Cultural & Language Data as Training Data
Oral histories, language recordings, and ceremonial knowledge must be explicitly excluded from AI training datasets. Vendors must sign binding agreements with audit rights to verify compliance.
Cultural Protection
Vendor Risk Assessment
AI vendors bring capabilities but also risks. Nations must evaluate every provider through a lens of trust, leverage, and long-term alignment.
Guidance
Use a Tribal AI Procurement Checklist
Before any contract, require vendors to answer: (1) Who owns the data we input? (2) Will our data train your models? (3) Where is data stored — and can it be subpoenaed? (4) What happens to our data if your company is acquired or shut down?
Procurement
Avoid Vendor Lock-In by Design
Require data portability and open export formats in every contract. Prefer vendors who support interoperability standards. Pilot before committing — especially for systems touching enrollment, health records, or child welfare.
Contracting
Tier Vendors by Sensitivity Level
Not all vendors need the same scrutiny. Use a 3-tier model: Tier 1 (touches member PII or cultural data) = full legal review + council approval. Tier 2 (internal admin/operations) = IT review. Tier 3 (general productivity tools) = staff review.
Risk Tiers
Community Impact
AI should strengthen — not fracture — community relationships, cultural continuity, and the social fabric of tribal life.
Guidance
Community Benefit Test Before Deployment
For every proposed AI use case, ask: Who benefits most? Who bears the most risk? Does this reflect community values? Could this displace community roles that carry cultural significance? Document answers before proceeding.
Values Alignment
Establish a Community AI Advisory Circle
Create a standing body — including elders, youth, program staff, and council members — to review and advise on AI initiatives. This isn't just due diligence; it's governance. Meet quarterly at minimum.
Governance Body
Identify High-Value, Low-Risk Starting Points
Good first uses: grant writing assistance, meeting transcription, document drafting, language learning apps (if language data is tribally controlled), and internal administrative tools. Avoid: member-facing decision systems, child welfare, law enforcement.
Use Case Selection
Workforce Upskilling
Sustainable AI adoption requires building internal capacity — so the nation remains the expert in the room, not a dependent of outside vendors.
Guidance
Identify an Internal AI Champion
Designate a staff member (IT director, data manager, or trained generalist) as the tribal AI lead. Fund their ongoing professional development. This person becomes the institutional memory and accountability anchor for AI initiatives.
Capacity Building
All-Staff AI Literacy (Not Just IT)
Program managers, health aides, educators, and council staff will all encounter AI. Provide a 2-hour foundational training: what AI is, what it isn't, how to spot AI-generated content, and how to report concerns. Use free resources from AI4K12 and MIT OpenCourseWare.
Training
Tribal College & Youth Pipeline
Partner with Tribal Colleges and Universities (TCUs) to develop AI curriculum that centers Indigenous values. Invest in youth tech pathways — the next generation of data stewards should come from within the community, not from Silicon Valley.
Long-Term Investment