Responsible AI Policy

The AICC’s Responsible AI Policy outlines our approach to AI development, adoption, advisory guidance, research & development, and ethical permissibility for AI in Northern Ireland.

Part 1: Our Values

  1. The AICC Team is united by a shared commitment to harnessing AI’s potential for good, solving real-world problems, and building a future where technology empowers people, businesses and communities.
  2. We believe our responsible AI values help define the way we work with AI. We aim to live our values and integrate them into our approach as we work across Northern Ireland.
  3. At the AICC, we:

Part 2: Our Principles

  1. Principles are the guiding rules that form the foundation of our decision-making and approach at the AICC. We rely on our AI Principles to:
  2. Our principles are how we take our responsible AI values into everything we do. We don’t believe that policies are just words on a page, we live our values and integrate them into our ways-of-working using these principles:

Part 3: Compliance with Legislation & Regulation

  1. The AICC is committed to the ethical, lawful and responsible development, deployment, and use of Artificial Intelligence (AI). The AICC will operate in accordance with the most comprehensive legislative and regulatory frameworks which are locally applicable.
  2. We will align all relevant AI workstreams and processes with the EU’s AI Act. This includes:
  3. We recognise the unique position of Northern Ireland which is influenced by the United Kingdom principles for AI, and by the Windsor Framework which maintains the applicability of certain EU law in specific context. As such, at the AICC:
  4. We will not engage in, support, or permit any AI use cases that are prohibited under the EU AI Act, including but not limited to:
  5. As per this Responsible AI Policy, projects within the AICC will:
  6. Any system approaching high-risk or restricted use will be subject to escalation, audit and review within the AICC.
  7. The AICC recognises that the use of AI intersects with sector-specific regulatory frameworks. Under the Transformer Programme, the AICC will ensure that AI systems comply not only with general AI laws, but also with industry-specific regulations, including but not limited to:
  8. All AI projects will be evaluated for compliance with relevant industry codes, standards, and best practices, with domain-oversight where appropriate.

Part 4: The Transformer Programme

  1. The AI Collaboration Centre’s Transformer Programme is a comprehensive 20-day journey designed to empower businesses with the tools and expertise needed to leverage artificial intelligence effectively.
  2. Through a blend of hands-on sessions and expert guidance participants will progress from understanding the fundamentals of AI to building and integrating tailored AI models into their operations.
  3. Our commitment in the AICC Transformer Programme:
  4. We will complete Core Assessments throughout the Transformer Programme to evaluate and advise on organisation and project compliance and governance. Where necessary this includes, but is not limited to:
  5. The list of activities outlined above is non-exhaustive. Where required and identified as necessary, the AICC team will provide additional support. This may include, but is not limited to:
  6. The AlCC will make consideration of your AI project / system during your organisation onboarding (see Considerations for Engagement with AICC in this policy), however, if the AICC find unacceptable risk following the ethical assessments during the active engagement, the AICC may need to re-evaluate its engagement under any agreement or Statement of Work.

SECTION 1: Governance – Lines of Responsibility in AICC

  1. We will establish and communicate the following lines of responsibility for all engagements with the AICC Transformer Programme.
  2. Defining the Levels of Responsibility
  3. Defining the Roles and Responsibilities in the AICC Transformer Programme
  1. All relevant personnel in the outlined roles are available via AICC.CO and will be highlighted in the communications for the Transformer Programme.
  2. f a team member is, or becomes unavailable, the AICC will communicate and adapt the lines of responsibility, as possible, to limit the impact on programme continuity.

Section 2: Governance – Communication of AI in Projects

  1. We believe that AI projects should include consistent, clear and transparent communications. Our communication should enhance the operational progress of our Transformer Programme. We will rely on effective communication to:
  2. The AICC will assign responsibilities for communication amongst its lines of responsibility, including communication with all organisation individuals and groups, and AICC project team members that are involved in the AI project lifecycle or those that may be impacted by its progress.
  3. During your engagement with the AICC in the Transformer Programme, there are two core phases of communication and engagement:

Section 3: Outcomes of the Transformer Programme

  1. The Transformer Programme works with you to help realise your AI ambitions, and will work to produce reports, insights, and in some cases technical based for Proof of Concept or Pilot.
  2. At the AICC we:

Part 6: Considerations for Engagement with AICC

  1. The Partnership Agreement outlines the terms and conditions under which the AICC agrees to work with SMEs. It details responsibilities and terms for the engagement and confirms the SMEs position on the AICC Transformer Programme.
  2. Engagement with SMEs in the Transformer Programme includes multiple assessments for assessing Ethics & Governance in AI work. However, the AICC may not engage with SMEs for the Transformer Programme, if:
  3. The list above is not explicit or exhaustive, these considerations are made before a project may progress into an active engagement within the Transformer Programme, however, may not always act as a barrier to engagement.

Part 7: High-Risk Areas & Corresponding Projects

  1. SME projects in the Transformer Programme may be considered ‘High Risk’. These projects will be continuously monitored throughout the engagement due to their sensitive nature.
  2. Projects which are identified as ‘High Risk’ may be subject to additional action or termination of the Partnership Agreement under the Transformer Programme.
  3. Projects which are classified as “High-Risk” are not prevented from engagement in the Transformer Programme, but approaches may impact the collaboration scope between the AICC and SME.
  4. ‘High Risk’ projects will be identified before the kick-off of the Transformer Programme engagement. These include:

Part 7: Privacy and Data Security

  1. At the AICC, we place a high priority on the protection of personal and sensitive data used in the development and operation of artificial intelligence systems. Our approach draws from recognised best practices in data privacy and information security, including principles reflected in standards such as the ISO/IEC 27001 (Information Security Management) and ISO/IEC 27701 (Privacy Information Management), while adapting to the specific needs of our organisation and the regulatory environment in which the AICC and its Transformer Participants operate.
  2. Data Minimisation and Purpose Limitation
  3. Data Anonymisation and De-Identification
  4. Consent & Transparency
  5. Secure Data Handling
  6. Third Party and Supply Chain Risk Management
  7. Data Quality and Integrity
  8. Outside of the Transformer Programme, the AICC believes that the following areas can help SME and AI projects avoid error propagation:

Part 8: Our 10 Don’ts for Responsible AI at the AICC

At the AICC, we:


Part 9: 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 development, deployment, education and adoption.
  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

Responsible AI

The practice of designing, developing, and deploying AI systems in ways that are ethical, transparent, fair, accountable, sustainable, and aligned with human rights and societal well-being.

Transformer Programme

AICC’s structured 20-day engagement journey designed to help SMEs understand, explore, and apply AI solutions effectively and ethically.

SME

Small and Medium-sized Enterprises – business engaged with AICC support through the Transformer Programme.

Values

Core beliefs guiding the AICC’s approach: Careful ideation (CARE), honest and fair development (INTEGRITY), and innovation built on dependable relationships (TRUST).

Principles

Operations guidelines shaping how the AICC applies its values to AI projects: ensuring equity (FAIRNESS), clear responsibility (ACCOUNTABILITY), long-term benefits and positive impacts (SUSTAINABILITY), and openness (TRANSPARENCY).

Compliance

Adherence to legal and regulatory requirements, particularly the EU AI Act, UK AI Principles, and sector-specific laws, ensuring AI systems are lawful and ethical.

EU AI Act

The European Union’s regulatory framework setting legal standards for AI based on risk levels, transparency, human oversight, and protection of rights.

Windsor Framework

Agreement impacting Northern Ireland’s regulatory landscape, maintaining partial alignment with EU rules post-Brexit.

CAGE

Core Assessment of Governance & Ethics which refer to evaluations conducted during the Transformer Programme (or outside of this programme), including Data Fact Sheets, Harm Assessments, Policy Review, and AI Project Review to ensure ethical compliance.

Data Fact Sheet

A structured document summarising the data used in an AI project, explaining its origins, limitations, and relevance to the project.

Harm Assessment

A structured evaluation to identify real-world risks, biases, and unintended consequences in AI projects.

Governance

The framework of roles, responsibilities, and oversight practices ensuring responsible and effective AI project management.

Primary Points of Contact

Individuals responsible for daily management and smooth operation of AI engagements during the Transformer Programme.

Escalation Points of Contact

Individuals responsible for addressing critical concerns that cannot be resolved by the primary points of contact.

Proof of Concept (PoC)

An AI prototype developed during the Transformer Programme to test and validate ideas before larger implementation or development.

Pilot

An experimental deployment of an AI with limited scope to assess feasibility, without guaranteeing final production deployment.

Exit Strategy

A define plan for the responsible conclusion or transition of an AI pilot or project, ensuring handover or decommissioning.

Ethical Permissibility

Evaluating and ensuring that AI projects are not only legal but also morally acceptable and socially beneficial.

High-Risk-AI Systems

Systems classified under the EU AI Act as posing significant risk to health, safety, fundamental rights, or democratic processes, requiring strict controls.

Prohibited AI Practices

AI Applications forbidden by law (e.g., subliminal manipulation, exploitative targeting, unauthorised biometric categorisation) as outlined in the EU AI Act.

Explainability

The ability to clearly explain how an AI system makes its decisions or predictions in understandable terms for users and stakeholders.

Accountability

The principle that humans, not AI, are responsible for outcomes and decisions made through AI systems.

Transparency

The principle of making AI usage, decisions, data sources, and risks understandable and visible to users and affected parties.

Sustainability

Ensuring that AI solutions are designed for long-term benefit, resource efficiency, maintainability, and positive societal impact.

Fairness

Ensuring that AI systems are free from bias, discrimination, or exclusion of individuals or groups.

Ethics & Governance Assessment

A structured evaluation performed by AICC to determine if AI projects meet ethical, regulatory, and governance standards.

Sector-specific Regulations

Laws and standards applying to specific industries (e.g., healthcare, finance, education) that AI systems must comply with in addition to general AI regulations.

Consent

Voluntary, informed, and clear agreement by individuals or organisations to the collection, sharing, and use of their data in AI projects.

Open

Dialogue

An engagement approach that encourages feedback, transparency, and shared understanding between AICC and SMEs during AI projects.

AI Redress Mechanism

Processes allowing individuals to challenge, correct, or seek remedies for adverse outcomes resulting from AI systems.

Dual Regulatory Obligations

The requirement to comply with both UK and EU AI laws where Northern Ireland operates under intersecting legal frameworks.

Data

Protection

Legal and ethical standards ensuring personal data is processed securely, fairly, and transparently (e.g., GDPR compliance).

Ethical Exit

A planned and responsible handover or closure of an AI engagement, ensuring no ongoing harm or abandonment of AI projects.

Reactive Compliance

Waiting for regulations to mandate action; contrasted with AICC’s proactive approach of anticipating and aligning with evolving standards.

ISO/IEC 27001 – Information Security Management

Provides requirements for establishing, implementing, maintaining and improving an information security management system (ISMS).

ISO/IEC27701 – Privacy Information Management

Provides guidance on managing privacy controls and building a privacy information management system (PIMS).

ISO/IEC 38505 – Governance of Data

Offers frameworks for the effective governance of data to support decision-making and compliance throughout its lifecycle.

Updated May 2025

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