Versatile AI Risk Assessment
Customer service, marketing and platforms

Recommender system

The system uses a person's behaviour and profile to select products, content or search results and determine their order.

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A concise PDF covering how the system works, its data flows and points to investigate, ready to share.

The explanations and measures describe the typical system design. Extensive personal changes add an appendix.

Understand the use case

What defines this use case?

The model learns from clicks, purchases and ratings what is likely to interest someone and ranks offerings accordingly. The OECD cites Amazon as a reference example, Netflix researches its recommendations' effects, and a Helsinki public library uses recommendations for books.

This page describes a typical system design. Actual data flows and permissions depend on your implementation.

System design
Analysis and processing
Ability to act
Provides results for subsequent use
Fields of use
online retail, streaming and media, libraries
Also known as
personalisation, product recommendations, ranking content and search results

How it works, step by step

System design and data flows

  1. Input data

    A person's clicks, purchases, ratings and profile details arrive continuously.

    Ratings, third-party sellers' offers and clicking behaviour come from outsiders and can be deliberately manipulated. The system analyses individual usage behaviour and profiles.

  2. Processing

    A model estimates how likely the person is to respond to a product or content item and selects the best matches.

    The model estimates which available content or products suit a person's current context. A ranking combines these estimates with platform rules, such as availability or diversity requirements. The recommendation therefore results from both model evaluation and selection rules.

  3. Results

    The system determines which products, content or search results appear and in what order.

    The result describes the defined model task. A match, category or forecast acquires its professional significance only in conjunction with the underlying data and intended use.

  4. Use and impact

    The selection shapes what people buy, read or watch and generates data for further learning.

    The model supplies information for subsequent use. Selection, adoption or a professional decision in the following workflow is a separate step and should not automatically be attributed to the model.

Explore the system design: Select a component to see its task, incoming and outgoing data, and role in the use case. The guided walkthrough explains each phase. Then use Yes, Uncertain and No to represent your specific system variant.

How the system is built

12 review first9 clarify9 baseline threats

InputProcessingResultImpact Externalaccess 50 Input 21 Third-partycontent 00 AI model 15 Providerservice 02 Documentcollection 10 Memory 00 Training andfeedback 30 OtherAI agents 00 Tools andinterfaces 00 Result 00 Business appor equipment 00 person 00 Affectedperson 00 AI serviceswithout approval 01 Externalaccess 50 Input 21 Third-partycontent 00 AI model 15 Providerservice 02 Documentcollection 10 Memory 00 Training andfeedback 30 OtherAI agents 00 Tools andinterfaces 00 Result 00 Business appor equipment 00 person 00 Affectedperson 00 AI serviceswithout approval 01
  • Present
  • Depends on your system
  • Absent
  • Review first
  • To clarify

In this system design: 12 to review first, 9 to clarify, 9 baseline threats.

Architecture as a list

How it differs from similar use cases

Data and information

Input data and information sources

Ratings, third-party sellers' offers and clicking behaviour come from outsiders and can be deliberately manipulated. The system analyses individual usage behaviour and profiles.

Processing and operating environment

The model processes the inputs. Whether it runs internally or with a service provider must be established for the specific implementation.

Storage and further use

The system selects products or content from a catalogue to match the profile. The deployer trains the model on usage data from its own service.

Results and data sharing

The system determines which products, content or search results appear and in what order.

Using a provider does not automatically determine where processing takes place. Storage location, subcontractors, deletion periods and use for training must be checked for the specific deployment.

Assess risks and determine measures

From understanding the system to analysing risks

  1. Define the system boundary

    Record data, participants, interfaces and permissions. Resolve uncertain characteristics in the model.

  2. Investigate threats

    Relate review candidates to actual data flows: what could happen, and who would be affected?

  3. Assess risk

    Assess impacts and likelihood in the deployment context. The number of review candidates is not a risk score.

  4. Provide evidence of measures

    Select appropriate controls, assign responsibilities and define effectiveness checks. Document residual risks and approvals.

Key threats in the application context

  • 3 particularly important
  • 9 typical
  • 9 depending on the system
  • 9 for every AI system

A total of 30 threats from the threat catalogue may be relevant to this use case.

Priority review points

  1. Misalignment

    The system learns that provocative or sensational content increases time spent and recommends more of it. Engagement rises while users see increasingly harmful content.

  2. Training Data Poisoning

    A seller creates artificial interest through purchased ratings and automated clicks. The model learns from this and prominently recommends the products to many people.

  3. Privacy Attacks

    The model infers pregnancy or illness from purchases and viewed content. Tailored recommendations reveal this to others sharing the device.

9 further review candidates in the typical design

Other relevant threats

  1. Targeted Poisoning / Label Poisoning

    Falsified training labels can deliberately shift model outputs.

    Listed because of this characteristic

    • Uses operational feedback
  2. Backdoor ML Model

    Training data or an adopted base model can introduce hidden triggers for misbehaviour.

    Listed because of this characteristic

    • Learns from your own data
  3. Model Theft

    Anyone able to query the model can replicate it through many queries. Internally trained weights can be stolen through network access.

    Listed because of this characteristic

    • Available to people outside the organisation
  4. Model Denial of Service

    Complex or high-volume inputs can exhaust model computing resources.

    Listed because of this characteristic

    • Available to people outside the organisation
  5. Cost Harvesting / Repurposing

    Paid or publicly triggered queries can be abused to consume computing resources and money.

    Listed because of this characteristic

    • Available to people outside the organisation
  6. Sensitive Information Disclosure

    Confidential content can appear in answers, supplied context or logs.

    Listed because of this characteristic

    • Processes personal data
  7. Application Denial of Service

    A network-accessible application can be overwhelmed by mass requests.

    Listed because of this characteristic

    • Available to people outside the organisation
  8. RAG-Specific Attacks (Document Poisoning)

    Content entering the retrievable knowledge collection can influence answers and subsequent steps.

    Listed because of this characteristic

    • Searches its own document collection
  9. Model Reconnaissance

    Targeted queries can reveal the model's architecture and safeguards.

    Listed because of this characteristic

    • Available to people outside the organisation

Up to 9 further threats may apply, depending on your system design. Nine threats need to be reviewed for every AI system.

System features and open questions

Each Yes adds further threats to your checklist, up to 9 in total. If you cannot yet answer a question, include its threats in your review.

How many threats a Yes adds
  • Added by this Yes

How your system is built

Does the system process confidential information such as trade secrets, health or financial data?

Purchases and viewed content can reveal health, religion or sexual orientation.

If yes, add

Does the system process several input types together, such as text with images or speech?

If yes, add

How you operate the system

These questions arise for almost every AI system.

Controls and implementation

Measures for the priority review areas are expanded. Each linked measure explains how to implement it.

Review priorityMisalignment3 measures
Review priorityTraining Data Poisoning2 measures
Review priorityPrivacy Attacks3 measures
Targeted Poisoning / Label Poisoning3 measures
Backdoor ML Model2 measures
Model Theft3 measures
Model Denial of Service3 measures
Cost Harvesting / Repurposing3 measures
Sensitive Information Disclosure3 measures
Application Denial of Service3 measures
RAG-Specific Attacks (Document Poisoning)3 measures
Model Reconnaissance3 measures

Controls for the remaining threats are available on their pages in the threat catalogue.

AI Act provisions

When AI Act provisions apply
  1. Art. 4: AI literacy

    For every AI system Applies since 2 February 2025.

  2. Art. 5 para. 1 point a, b: Manipulation and exploitation of vulnerability

    Depending on use Review trigger since 2 February 2025.

Applies to every AI system

Art. 4: AI literacy

Applies if staff or appointed representatives operate or use AI systems.

Applies since 2 February 2025.

Obligations and details for Art. 4: AI literacy
Who bears the obligations
Provider, Deployer, Product manufacturer, Provider of a general-purpose AI model

Detailed obligations

May apply in particular uses

Art. 5 para. 1 point a, b: Manipulation and exploitation of vulnerability

Applies if the system deliberately exploits vulnerabilities due to age, disability or economic circumstances in a way that risks significant harm.

Applies since 2 February 2025.

Obligations and details for Art. 5 para. 1 point a, b: Manipulation and exploitation of vulnerability
The general condition is
Applies if the system influences behaviour through subliminal, manipulative or deceptive means, or exploits vulnerability due to age, disability or social or economic circumstances, with a risk of significant harm.
Who bears the obligations
Provider, Deployer, Importer, Distributor, Authorised representative, Product manufacturer, Provider of a general-purpose AI model

Detailed obligations

Other legal requirements

  • Article 27 DSA

    Online platforms must disclose in their terms and conditions the main parameters their recommender systems use to select and rank content.

    Open the legislation Article 27 DSA

Classify your system with the quick checker All obligations in the obligations compass

Cross-cutting threats

Review these threats for every AI system, whatever its purpose.

Why these threats always belong on the checklist

Atypical system features

View 14 further questions

If any of these features does apply to your system, add the listed threats.

Sources

Related use cases

Also in the field of Customer service, marketing and platforms

Often used together with

Updated: 30 September 2026. Review checklist rules version 0.3.2, threat catalogue version 2026.10.24.2. How these pages are structured