Insights ¦ Internal AI Use Policy

Key Take Aways

1. The ICO recognises AI as a means to enhance decision-making, streamline operations, and improve stakeholder engagement while maintaining responsibility and transparency.
2. Responsible AI adoption at the ICO is guided by principles of ethics, transparency, and alignment with core values, ensuring risks are proactively managed.
3. All ICO employees and contractual third parties must understand and adhere to the organisation’s AI policies, especially section 4, which details required governance.
4. Use of AI tools is only permissible if approved through ICO’s governance processes, including proper documentation and human review of outputs.
5. AI deployment involving personal or sensitive data requires careful compliance with data protection legislation, including mandatory Data Protection Impact Assessments (DPIAs).
6. The organisation emphasises ongoing AI literacy and tailored training to ensure staff understand AI limitations, opportunities, and ethical considerations.
7. A comprehensive governance framework assigns accountability for AI risks to specific roles, with decisions and risks rigorously logged and documented.
8. Impact assessments addressing fairness, explainability, and equality are mandatory for all AI initiatives, particularly those affecting individuals or groups.
9. Transparent documentation and regular performance monitoring are essential for ensuring AI systems meet safety, security, and operational standards.
10. The organisation advocates early and continuous stakeholder engagement, including mechanisms for feedback, incident reporting, and redress processes.
11. AI lifecycle management encompasses validation, re-evaluation, and retirements to mitigate obsolescence and ensure ongoing effectiveness.
12. The policy underscores compliance as vital, with non-conformance potentially exposing individuals to disciplinary, civil, or criminal liabilities.

Key Statistics

• The AI policy is documented as version 1.1, published on 20 August 2025.
• The policy mandates review every year, with the next scheduled for August 2026.
• AI tools must pass verification and validation before deployment, with detailed technical documentation required.
• All AI initiatives involving personal data must involve DPIAs, aligning with ICO guidance on data protection and AI.
• The policy applies broadly to all forms of AI, including embedded, bespoke, or third-party solutions, whether deployed in pilot or production environments.

Key Discussion Points

• The primary goal is maximising benefits of AI at the ICO while minimising associated risks through robust governance.
• The policy highlights the importance of transparency, documentation, and human oversight in AI outputs and decision-making processes.
• Use of AI must align with existing legal frameworks, including data protection laws and equality duties, reinforced by specific impact assessments.
• Formal approval procedures are essential prior to AI development, procurement, or deployment, especially when involving sensitive data or automation.
• The policy promotes proportionality, allowing fast-track approval routes for low-risk AI applications once assessments confirm minimal risks.
• Logistical requirements include maintaining an AI inventory, decision logs, and evidence of continuous performance monitoring.
• Ensuring fairness and explainability is central to AI use, with specific mention of impact assessments, equality impact evaluations, and fairness considerations.
• It advocates for a layered approach to AI verification, validation, and ongoing performance scrutiny to safeguard safety and robustness.
• Stakeholder engagement involves mechanisms for feedback, incident reporting, and redress, especially where AI influences decisions or public interaction.
• Any significant change to AI solutions is treated as a new use case, with regular reviews supporting lifecycle management.
• Breaches of this policy can result in disciplinary or legal actions, underscoring the organisational emphasis on compliance and responsible AI use.
• The document provides detailed annexes setting out screening templates, specifications, and foundational knowledge on AI concepts relevant to ICO staff.

Document Description

This article is an internal policy document from the ICO, providing comprehensive guidance on responsible AI use within the organisation. It outlines principles, governance structures, procedural requirements, and ethical considerations for deploying AI tools. The policy covers the entire lifecycle of AI systems—from development and procurement to re-evaluation and retirement—emphasising transparency, accountability, and safeguarding data protection obligations. It aims to enable ICO staff and third-party contractors to leverage AI responsibly, ensuring benefits are maximised while mitigating risks diligently, aligning with regulatory and organisational standards.