AI Public Policy

a. This policy outlines the ethical use of Artificial Intelligence (AI) technologies within Acuigen ("Acuigen", "we", "our" and "us") and our client feedback platform, the CustomServe Intelligence Platform (including its website, CustomServe.com).

b. It applies to all employees of Acuigen and users of CustomServe (“Users”, “Clients”).

c. Acuigen may utilise third-party AI services, including Microsoft Azure AI services (configured with enterprise-grade security controls), Claude Team provided by Anthropic, and Adobe products, in accordance with this policy. Under our commercial terms with these providers, our data, and our clients’ data is not used to train their generative AI models.

Many everyday software products now include AI features, making it hard to avoid AI entirely. At Acuigen, we group our use of AI into three layers:

a. Common desktop software products, powering features such as predictive text in Microsoft Office or Adobe products. These are standard, non-generative features embedded in everyday software.

b. Microsoft speech and language services, used by Acuigen to support transcription, speech recognition and translation when handling client feedback interviews. These services transcribe and translate what was said rather than generating new content and are distinct from generative AI. They include the transcription built into Microsoft 365, such as Microsoft Teams and SharePoint, and Microsoft's Azure-hosted speech services. These services have previously been branded Microsoft Cognitive Services and Azure AI Services.

c. The CustomServe Intelligence Platform’s generative AI capabilities, using Azure OpenAI, together with Acuigen's internal productivity tools, including Microsoft Copilot, Azure OpenAI and Claude Team for administrative functions, drafting, analysis and summarising.

a. All AI technologies used within Acuigen will comply with applicable UK legislation, including the Data Protection Act 2018, the Data (Use and Access) Act 2025, the UK General Data Protection Regulation (UK GDPR), the Equality Act 2010 and the Human Rights Act 1998.

b. Acuigen will monitor developments in UK AI regulation and guidance issued by relevant regulators, including the Information Commissioner's Office (ICO), Equality and Human Rights Commission (EHRC), and other applicable authorities.

c. Some aspects of compliance and security are supported by our approved AI service providers. We select and assess providers with regard to their security, privacy and regulatory commitments, while remaining responsible for our own use of their services.

a. AI technologies will be used in a manner that respects human rights, diversity, and the personal dignity of all individuals. We use the built-in safeguards of our approved AI providers to reduce the risk of unfair bias and to support ethical use.

b. We are committed to monitoring and reporting any issues that arise.

a. Acuigen encourages users of CustomServe to review and edit AI-generated outputs before relying upon them for business decisions, reporting or client communications.

b. Acuigen will not permit its internal AI systems to make significant business, employment, or client decisions without appropriate human review.

c. Users remain responsible for decisions made using AI-generated content.

a. We commit to being transparent about our use of AI.

b. For each Client of Acuigen using CustomServe, we will provide a statement on our use of AI, and associated risk assessments.

c. Clients should review and, if needed, edit AI-generated content to ensure its accuracy. Additionally, clients should consider informing readers where content generated through CustomServe has been materially assisted by AI, particularly where transparency is required by professional, regulatory or contractual obligations.

d. Clients remain responsible for determining whether disclosure of AI-assisted content is appropriate, taking account of their professional, regulatory, legal and contractual obligations.

e. Where AI systems are used within CustomServe to make suggestions or recommendations based upon interview content, we will make it clear to clients when AI is being used.

f. We use Microsoft speech and language services to support our business processes, including the recording, transcription and translation of interviews and meetings. They include the transcription built into Microsoft 365, such as Microsoft Teams and SharePoint, and Microsoft's Azure-hosted speech services.

g. We use Claude Team, a generative AI assistant provided by Anthropic under its commercial terms, to support internal productivity tasks such as drafting, analysis and summarisation.

h. CustomServe AI Guard lets clients disable the use of Generative AI within CustomServe when processing respondent-provided content (such as an interview transcript). It can be applied at three levels: (1) an entire client site, (2) an individual client (for example, by organisation name), or (3) a single interview.

a. We will protect the privacy of individuals’ data; CustomServe is designed and used in a way that respects the privacy rights of individuals.

b. Users of CustomServe should avoid submitting to CustomServe unnecessary personal, confidential, or special category data to AI systems.

c. When users of CustomServe apply CustomServe AI Guard to specific interview content, it is excluded from processing by CustomServe's generative AI features. This flag applies only to CustomServe's generative AI features. It does not affect the other tools described in the 'How we use AI' section, such as Microsoft speech and language services or AI features in Microsoft Office.

d. Acuigen utilises approved third-party AI service providers and seeks to ensure that data processed by those services is handled securely and in accordance with applicable legislation.

e. Data submitted by CustomServe to AI services will be minimised, may be pseudonymised or anonymised where reasonably practical and consistent with the intended purpose.

f. Certain AI-assisted functions may require relevant information to be processed by approved AI services in order to provide meaningful analysis or insights. Acuigen seeks to minimise the personal data shared with such services wherever reasonably practicable.

g. It is not practical to anonymise personal information stored within verbatim comments that may be processed by AI.

h. Where client data is processed using internal generative AI tools, it remains subject to the same confidentiality obligations and data protections as all other client data handled by Acuigen, and is not used by the AI provider to train its models.

a. We will hold ourselves accountable for the provision of the CustomServe Intelligence platform.

b. We will make our clients aware that AI is an evolving technology and is not error free; it should therefore be used with appropriate professional judgement.

c. AI-generated content may contain inaccuracies, omissions, outdated information, or fabricated content ("hallucinations"). All outputs from CustomServe that have been created using AI should be independently reviewed by users of CustomServe and validated before use.

d. We will monitor and periodically audit the use of AI services provided by CustomServe.

a. We will continually learn and adapt our use of AI as the technology and its societal implications evolve.

b. We commit to staying informed about updates and changes in the technologies and policies of our AI providers, and we will adapt our use of these services accordingly.

c. We will regularly review this policy to ensure it remains relevant and effective.

a. We will provide appropriate training for all Acuigen staff who interact with our AI systems, to ensure they understand how to use these systems ethically and effectively.

b. This training will include, where appropriate, information on how to use Azure OpenAI and Claude Team.

a. To unlawfully discriminate against individuals or groups.

b. To generate misleading, deceptive, or fraudulent content.

c. To process personal data in a manner inconsistent with applicable data protection legislation.

d. To make fully automated decisions that have legal or similarly significant effects on individuals without appropriate safeguards.

e. To generate content intended to misrepresent Acuigen, our clients, or other individuals.

f. To process information where use of AI would be prohibited by law, regulation, contractual obligation, or Client instruction.

a. This policy is intended to ensure that Acuigen uses AI technologies in a way that is legal, ethical, and respectful of the rights and interests of all individuals.

b. While we have limited ability to influence third-party AI providers directly, we emphasise the importance of maintaining ethical standards in our use of their services.

c. We have feedback mechanisms in place to address any concerns related to the use of third-party AI services.

d. This policy may be reviewed and updated periodically to reflect changes in technology, legislation and business practices.