A healthcare organization is implementing an AI system for patient data management.

The best answer is A. Conduct a comprehensive data protection impact assessment . PMI-CPMAI explicitly includes conducting privacy impact assessments as part of overseeing the privacy and security plan for AI initiatives. It also includes ensuring compliance with GDPR, CCPA, and other data protection regulations, establishing governance protocols for PII, and implementing encryption, access controls, and secure data handling procedures. In a healthcare setting, where patient data is sensitive and highly regulated, a privacy or data protection impact assessment is the most appropriate first action because it identifies privacy risks, access-control concerns, regulatory exposure, and required safeguards before controls are formally implemented.

Option B is important, but governance frameworks should be informed by the assessment findings. Option C comes after the organization understands what protections are required. Option D may support long-term oversight, but assigning a role is not the first direct action for evaluating compliance obligations in the project itself. PMI’s trustworthy AI domain clearly prioritizes privacy assessment and regulatory compliance as foundational activities, making the impact assessment the strongest and most defensible first step.