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Data Usage Policy

The AICC’s Data Usage Policy outlines our approach to the information used and shared for AI development, adoption, advisory guidance, research & development, and ethical permissibility for AI in Northern Ireland.

Working with Data in the AICC

  1. The information we work with depends on how you interact with use, the services you use, and what you choose to share. In the Transformer Programme we collect information about your organisation in various ways, including information you provide directly, information collected automatically, information from publicly available sources, and data we infer or generate from other data.
  2. We’re committed to providing collaboration that is innovative, personal to your organisation needs, and responsible. To do that, we use your information to provide the necessary services within the Transformer Programme.
  3. We will only use your data for legitimate purposes, meaning that we have a “lawful basis” for processing the information. This includes, but is not limited to, consent, contract, legal obligation, vital interests, business interests, and delivery of the AICC Transformer Programme.
  4. Recipients may use the information only in accordance with the terms set out in this policy, other AICC policies (like the Responsible AI Policy), any project agreements.

Categories of Data and the AICC

  1. When collaborating with the AICC, the following categories of information may be shared:
    1. Project-Specific Data which may include:
      • Data and documentation directly related to the collaboration’s objectives.
      • Outlined examples: Project proposals, deliverables, and progress to-date; Proposed datasets (e.g., cleaned, aggregated, anonymised); Case studies, user feedback, and descriptions related to project scope.
      • Purpose: To enable project planning, analysis, design & development, validation, or communication.
    2. Technical Data which may include:
      • Technical and operation information necessary to enable interoperability, development, or integration activities.
      • Outlined examples: System architecture diagrams, data models, APIs, and integration guidelines; Technical documentation like use guides or user manuals; Specifications for software or hardware, or infrastructure; Code sample, versions, histories,
      • Purpose: To allow technical implementation, development, customisation and evaluation during collaboration.
    3. Operational Data which may include:
      • Logistical and operational materials relating to managing and coordinating the collaboration.
      • Outlined examples: Work plans, schedules, roadmaps, and milestones; Risk registers, resource plans, or task assignments; Communications and workflow diagrams.
      • Purpose: To ensure effective project management, tracking, coordination and communication during collaboration.
    4. Confidential Information which may include:
      • Sensitive, non-public information disclosed in the context of the collaboration.
      • Outlined examples: Internal policies, strategies and unpublished intellectual property; Business forecasts or market research; Personnel information (where relevant and permitted); Contracts and ancillary engagements or collaborations.
      • Purpose: To provide deeper context and strategic alignment during the project.
    5. Other Information may be shared depending on the project which may include:
      • Training materials or branding data; Data collected in pilots or testing; compliance documents (e.g., GDPR assessments, ISO certifications); any other data or information types agreed for the purposes of the collaboration.
      • Purpose: To support collaboration activities which may not be covered in the previous outlined categories.

Our Data Commitments at the AICC

  1. When collaborating with the AICC, we will commit that:
  2. Provision of information does not transfer ownership of any intellectual property rights.
  3. All information designated as “confidential”, or which by its nature should be reasonably understood to be confidential, will be treated as confidential and not disclosed except as permitted by this Policy or by express agreement.

Limitation on Data Usage at the AICC

  1. Information provided during collaboration with the AICC may only be used for defined purposes which are aligned between the AICC and its collaborators or partners.
  2. Information will not be used for:
    1. Commercial gain outside of the defined project; or
    2. Public disclosure or publication without written consent from the parties; or
    3. Development of competing products or services; or
    4. Any unlawful or unauthorised purpose.
  3. Any use beyond the originally agreed purpose requires written consent between the parties.

Data Retention at the AICC

  1. We keep information only so long as we need it to provide our services to you, fulfil the purposes described in this policy, comply with our legal obligations, resolve disputes, and enforce our agreements.
    1. Actual retention periods can vary based on your expectations and consent, the sensitivity of the data, the availability of controls, and our legal or contractual obligations.
    2. Actual retention periods can vary based on several factors, including:
      • Your Expectations and Consent: The AICC will consider your preferences regarding how long your information should be retained, particularly where you have provided specific consent for ongoing use or requested early deletion.
      • Sensitivity of the Data: More sensitive information (such as confidential, personal, or commercially sensitive data) may be subject to shorter retention periods or stricter deletion protocols.
      • Availability of Controls: Where possible, the AICC implement retention controls to ensure information is not kept longer than necessary.
      • Legal and Contractual Information: Certain information may need to be retained for a defined period to comply with applicable laws or to comply with agreed obligations between parties.
  2. The AICC will regularly review the data we hold to ensure it remains relevant, accurate, and necessary. Where information is no longer required, we will securely delete, anonymise, or otherwise dispose of it in a manner that maintains confidentiality and prevents unauthorised access.
  3. Information will not be retained beyond the lifespan of the Artificial Intelligence Collaboration Centre (“AICC”).
    1. If the AICC ceases operations or is otherwise dissolved, all retained information will be securely and permanently deleted, unless required to be preserved by law for a specific period. No personal, project, or operation data will continue to exist beyond the legal and operational existence of the AICC.
    2. If the AICC ceases operations, and merges without another entity, or passes its activities to a successor organisation, the information held by the AICC may be transferred to that successor. This will only happen if:
      • The successor needs the information to continue the same purposes for which it was collected; and
      • The successor agrees to protect the information to at least the same standard as outlined in this policy; and
      • Organisations or Individuals (where applicable) are informed about the transfer, and their rights are respected.
  4. Where data has been aggregated or anonymised so that it can no longer be linked to an identifiable individual or specific project, we may retain such information for analytical, research, or statistical purposes indefinitely, without further notice.
  5. We are committed to validating and sharing our experiences in AI for SMEs in Northern Ireland. We publish only using aggregated, de-identified data. If you would not like your information to be used in our studies, please fill out the ‘Opt-out of AICC research form’.

Updating & Maintaining this Policy

  1. This Policy will be reviewed and updated on a regular basis to ensure it remains aligned with the latest developments in Responsible AI practices, ethical standards, and the evolving impact of AI in real-world context.
  2. Reviews will consider emerging regulatory requirements, advances in technology, societal expectations, and organisational learnings from AI deployment.
  3. Updates to this Policy will be made to reinforce ethical permissibility, promote responsible innovation, and mitigate any identified risks associated with AI systems in use.

Glossary of Terms

Information
Any data, documentation, or materials collected during the Transformer Programme collaboration.
Personal Data
Information that relates to an identified or identifiable individual.
Confidential Information
Non-public data such as strategies, business plans, or IP.
Project-Specific Data
Data directly related to project objectives and deliverables.
Technical Data
Operational information supporting integration, development, or implementation.
Operational Data
Logistical materials for project management like schedules and workflows.
Other Information
Additional data outside standard categories like training materials or compliance documents.
Processing
Operations on information including storage, use, sharing, and deletion.
Data Breach
Unauthorised access, loss, or disclosure of managed data.
Retention
Duration information is held before secure deletion or anonymisation.
Anonymised Data
Data altered so it cannot identify an individual or entity.
Aggregated Data
Summary data that does not identify individuals or organisations.
Successor Organisation
An entity assuming AICC operations and obligations post-closure.
Applicable Law
Relevant laws and regulations governing information processing.
Third Party
Any entity not directly partnered with the AICC.
Opt-Out Mechanism
Formal request to exclude one’s data from research/publication.
Research Publication
Findings shared publicly based on de-identified, aggregated data.

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