Cardio Flow Design AI Governance

Bringing World-Class Trust
to the Future of Medical AI.

Cardio Flow Design Co., Ltd. develops and operates safe, compliant medical AI under the guidance of our U.S. legal counsel, grounded in rigorous compliance standards and a state-of-the-art governance framework.

The Eight Pillars of AI Governance
Practiced at Cardio Flow Design

As a high-capability AI company handling sensitive medical data, we implement and maintain the following rigorous governance framework across the entire organization.

1. Comprehensive AI Mapping

We map and maintain a complete inventory of all AI models deployed across our organization and supply chain, managing them through a centralized registry.

2. Clear Accountability & Reporting Structure

An internal AI Committee comprising Legal, Engineering, and IT divisions operates with direct executive approval authority and defined reporting lines to senior leadership.

3. Risk Assessment Process

Before introducing any new AI product or development vendor, we conduct pre-screening for risks including AI malfunction, hallucination, and discriminatory bias.

4. Internal AI Policy Formulation

We have codified a company-wide AI Governance Policy focused on intellectual property protection, personal and confidential data protection, and equitable healthcare access.

5. Ongoing Employee Training

We conduct regular training for all software engineers and staff covering generative AI risks and compliance obligations.

6. Monitoring & Internal Audit

We conduct log-based audits of AI tool usage across development and daily operations to promptly detect any unauthorized or non-compliant activity.

7. Incident Response Preparedness

We maintain a rapid-response protocol for unforeseen events such as AI system failures or data breaches, designed to minimize impact and ensure immediate reporting to relevant authorities.

8. Continuous Governance Updates

We conduct annual reviews and optimizations of our governance framework based on amendments to AI-related laws in Japan, the U.S., and Europe, as well as the latest case law developments.

Eliminating Shadow AI and Defending Trade Secrets & Intellectual Property

"Shadow AI" — the use of personal generative AI tools (such as ChatGPT) without company authorization — poses a critical risk of leaking proprietary information, source code, and even de-identified patient data.

We systematically restrict unauthorized AI access from all company devices and have deployed mechanisms that automatically warn users against entering confidential information even if access is attempted. This is an essential defense to fully satisfy the standard of "Reasonable Efforts to Maintain Secrecy" — the most critical threshold in U.S. trade secret litigation — thereby safeguarding our intangible intellectual assets.

Preparedness for U.S. Litigation Discovery Procedures

A history of casual queries submitted by executives or engineers to personal AI tools can, in the event of IP litigation, be compelled as evidence of willful misconduct or gross negligence during the discovery process. Cardio Flow Design advances a legally airtight AI development process while properly maintaining Attorney-Client Privilege.

Securing Safety Across the Entire Supply Chain

Cardio Flow Design's approach to AI safety extends beyond our own internal development. We also require all collaborative partners, external vendors, and suppliers to adhere to our high governance standards.

Contract templates reviewed by our U.S. legal counsel include globally rigorous "AI Use Management Clauses" that strictly prohibit suppliers from using generative AI without authorization, or from using our data and confidential information to train or fine-tune AI models.

This ensures that we can demonstrate unshakeable end-to-end safety across the entire supply chain to governments and international healthcare institutions.

Generative AI Management Clause Template Applied to Partner Vendors (English Original)
Supplier shall not use any generative artificial intelligence, large language models, machine learning systems, or other artificial intelligence tools or services in connection with the provision of the Services or the processing of Customer Data without providing at least ninety (90) days prior written notice to Customer and obtaining Customer's prior written consent. If Customer provides such consent, Supplier shall not use any Customer Data, Customer Confidential Information, or Deliverables to develop, train, fine-tune, test, improve, or otherwise enhance any artificial intelligence or machine learning models, systems, or services. Supplier shall implement reasonable safeguards to protect Customer Data and Customer Confidential Information and shall remain fully responsible for all Deliverables and outputs generated using such artificial intelligence tools or services.

* This clause creates an extremely robust defense: it completely bars the use of our customer data and confidential information for AI training, and even when AI use is permitted, it places full responsibility for all deliverables squarely on the supplier.

High Ethics and Governance Are Non-Negotiable in Medical AI Development.

As a company developing cardiovascular software that directly affects people's health and lives, we will continue our journey as a world-class AI company — one that unites cutting-edge technical capability with an unwavering commitment to safety. If you are a client or partner with questions about our AI governance framework or U.S. regulatory compliance, please feel free to reach out at security@cfd.life