Charity AI Policy - Governance & Ethics Framework

AI for charities - the Charity AI Governance & Ethics Framework - a simple, practical template for your charity to create an AI policy

Charity AI Policy - Governance & Ethics Framework

The Charity AI Governance and Ethics Framework is a simple, practical template for your charity to create an AI policy to manage the legal, compliance and ethical challenges of charity AI use.

AI governance and ethics is a very complex and fast evolving area, but very soon, all of us in the charity sector will either be using AI or our work will be impacted by systems that use it and the huge uncertainties and risks are now widely accepted.

To support the charity sector in responding to this, we used our own AI ethics policy and procedures, informed by the work of others, to create this Charity AI Governance & Ethics Framework.  This is a living document - any comments/suggestions would be very welcome.  Send these to me at ian@charityexcellence.co.uk.

If you have any questions about AI or our charity AI services, click the AI bunny icon in the  bottom right of your screen and ask it short questions, including key words.

TRUST IN CHARITIES

In the charity sector, trust has always been critical.  We need people to trust us to feel able to use our services and we need the public and donors to trust us to be willing to provide the funding needed for our services.   However, AI will bring new and substantial challenges.  We will publish new work in Mar 25 to update our Governance and Ethics guidance to support charities in meeting this growing threat.

CHARITY AI - THE RISKS

This is the charity AI risk assessment we created for our own charity, which informed our work in creating this AI Framework. And we also have another toolkit to check if your charity is at particular risk, plus what you can do about it if you are.

CHARITY AI GOVERNANCE AND ETHICS FRAMEWORK

This framework is a simple, practical and flexible template for anyone using AI in the charity sector.  Simply add, amend or delete to meet your needs.

How To Use The Charity AI Governance Framework

This AI framework can be used by charities and non profits to:

  • Create an AI governance framework or policy for your charity and/or.
  • Embed relevant aspects in your existing policies and procedures, such as.
    • Data protection, Equality, Diversity & Inclusion (EDI) and ethical fundraising policies.

For those designing, commissioning or funding AI, it can be attached to RFPs, contracts and grants agreements, or relevant extracts included within these.

Charity AI Governance and Ethics Policy

This AI governance and ethics framework has been developed to ensure that the use of AI within our charity is ethical and legal, by meeting high standards of fairness, accountability, transparency, privacy, and non-discrimination in developing, running, and overseeing any AI systems we commission, create, develop, manage or use.

Applicability of This Policy

This policy applies to all trustees, other volunteers, employees, contractors, and third-party representatives working on our behalf.  Its requirements should be reflected in other policies and procedures, agreements and contracts, as necessary.

AI Definition

We define Artificial Intelligence (AI) as the ability of machines or software to perform tasks that would normally require human intelligence. AI systems can process data, learn from it, and make decisions or predictions based on that data.  AI is a broad field that encompasses many different types of systems and approaches to machine intelligence, including rule-base AI, machine learning, neural networks, natural language processing and robotics.

AI Governance

  • All key AI decisions and proposals will be subject to scrutiny and approval by the trustee Board.
    • They will be advised on any concerns or breaches in AI use and.
    • Will review this policy and our AI performance annually to keep up with evolving AI technologies and ethical standards.
  • Use of AI by our charity will have appropriate human oversight with humans being responsible for making all final decisions on their output.

Management of Charity AI

We will create any necessary guidelines:

  • On the collection, use and storage of data, including a data management strategy that outlines how we will manage and protect personal data.
  • To ensure accountability for the decisions made by AI systems, which may include measures such as auditing, reporting and review processes.
  • On the use of algorithms in decision-making, including the steps we will take to ensure these are as fair and unbiased as reasonably possible.

We will ensure that:

  • Those developing, running or overseeing AI have the necessary skills and experience to ensure that our AI governance policy is consistently complied with.
  • We provide any necessary training, awareness programmes and/or guidelines to support this.
  • AI governance is embedded in other relevant policies and procedures, contracts, agreements and other documentation, such as job descriptions.
  • Those with responsibilities for or involvement in AI, understand the policy, their responsibilities in delivering this and are accountable for doing so.

Charity AI Risk Management

Our AI risk analysis has included:

  • Any specific groups who may be at risk, whether individuals, groups, society generally or the environment.
  • Other reasonably foreseeable uses of the technology, including accidental or malicious misuse.
  • Whether a bias been created or reinforced within the system.

The risks have been clearly identified and quantified, and the avoidance/mitigation action put in place will ensure that the level of risk remains within acceptable limits.

You can use our Charity AI Risk Toolkit to better understand AI risks and create your own AI Risk Register, if you wish to.  There is also a supporting toolkit of AI Design principles for those building or commissioning AI systems.

Use of AI in Fundraising

We think we are likely to see AI development focussed on fundraising, simply because it is the area of greatest need and people are more likely to be willing to pay, so companies will focus on this.

  • If using AI with our CRM, we have carried out a data protection impact assessment and updated our data protection policy and procedures to reflect this.
  • We have created an AI best practice guide for funding bid writing.  If using AI to draft fundraising content, such as funding bids, these are always reviewed by a human for.
    • Tone/style/spelling, and to ensure.
    • Factual accuracy and that.
    • All relevant information has been included.
    • For funding bids, we also ensure compliance with any funder instructions relating to AI.
  • If using AI bots to fundraise, we will ensure there are built in safety systems, reporting and oversight to safeguard vulnerable people from exploitation by the AI.

Imagery Ethics

  • We will ensure that our use of AI and any other imagery, is ethical.
  • If we use AI generated, stock or digitally enhanced imagery, particularly where the subject may be emotive or challenging, we will ensure that the way in which we do so is not reasonably likely to mislead and, potentially, influence people.
    • For example, we may make our policy on its use publicly available and use watermarks, alt text and/or footnotes and/or explain this in content text.
  • We may not do so where its context and/or content is unlikely to mislead or influence. For example, an image of intergalactic war or use of a stock image on a post about opening hours.
  • We recognise that AI deep fakes can be difficult to identify but those using our social media will be made aware of the risk.
    • We will not like, share or support in the comments any imagery or content that we reasonably suspect to be fake.

Charity AI - Data Protection & Privacy

We have carried out a Data Protection Impact Assessment (DPIA) for AI and made any necessary changes to our policies and procedures.  As part of that, insofar as reasonably possible, we will:

  • Use accurate, fair, and representative data sets to ensure these are inclusive.
  • Not include personal data in data sets, or at least pseudo-anonymise or de-identify it.
  • Ensure that people know that sensitive personal data is not to be entered into AI systems and.
    • Have opted out of ChatGPT and/or DALL-E data sharing using this google doc) and.
      • If using an API, have not opted in to data sharing.
    • Or have switched off data sharing in their ChatGPT settings (bottom left corner of screen) - it isn't exactly prominent.
  • Reflect our use of AI in our privacy statements to ensure users know:
    • When their data is being used by AI.
    • Whether AI is making decisions about them and.
    • If so, what these decisions are.

We are aware of the ICO guidance on AI and data protection and have reflected any additional requirements in our policies and procedures.  For more on this, you can use our Charity AI Data Protection Toolkit.

Managing Change & Job Design

  • We support our people in adapting to the changes in our organisation AI will bring and.
  • Provide them with skills development, to enable them to use AI to achieve even more of the fantastic work they do.
  • We take into account the needs of our staff, including the need for human agency, when designing roles and work procedures.

Here is our assessment of the impact of AI on charity sector jobs and what charities need to think about and do in integrating AI into roles and procedures.  The Institute for the Future of Work has created a Good Work Algorithmic Impact Assessment that may be of interest, including 10 dimensions of 'good work'.

Charity Ethics - Beneficiaries & Other Stakeholders

  • We are committed to genuinely engaging with our stakeholders to ensure that our AI is aligned with their needs and values.
  • We factor in to our risk analysis any exclusion or detriment to them based on their identity.
  • We take reasonable steps to avoid or minimise any exclusion or detriment and transparently communicate this.
  • We will ensure that the content created:
    • Respects the dignity of individuals and.
    • Represents them in the way they would wish to be.
      • Including being accurately depicted in AI generated imagery.
        • For example, disability equipment or religious dress.
  • We will make our systems and content as accessible as possible.
  • Insofar as reasonably possible, we will:
    • Use accurate, fair, and representative data sets to ensure these are inclusive.
    • Not include personal data in data sets, or at least pseudo-anonymise or de-identify it.
    • Reflect our use of AI in our privacy statements to ensure users know:
      • When their data is being used by AI.
      • Whether AI is making decisions about them and.
      • If so, what these decisions are.

Charity AI Ethics

  • All reasonable efforts have been made to identify any bias within the system, including the source data it might use.
    • This bias has either been eradicated or mitigated to the point where it is within an acceptable level of risk.
    • We are open and transparent about any bias within the system and how we manage this.
  • Where AI is used to create content, there are appropriate checks and safeguards in place to ensure:
    • We are open and transparent that the content has been created by AI.
      • You might consider adding a footnote to any text and/or tagging imagery as 'authentic', 'partially AI created' or 'entirely AI created'.
    • Factual and non-factual content is either self-evident or clearly identified.
    • It will not be used, for purposes where the use of AI has been specifically not permitted.
    • We provide appropriate recognition for any material that was produced by others and used, in prompts or in other ways, in creating content.
    • There is appropriate content moderation by humans, to minimise the potential for errors and bias/defamatory phrases etc.

Charity AI Legal Compliance

We will ensure that:

  • For material we use that has been produced by others, we have their copyright agreement or.
  • We:
    • Do not knowingly use any online material, such as from social media accounts or online galleries, that has been marked as 'NoAI', 'NoImageAI', or similar.
    • Do not have a negative impact on the legal rights and/or liberties of individuals or groups.
    • Comply with the Data Protection Act, particularly the safeguarding of sensitive personal information.
      • The ICO guidance on AI and data protection has been reflected in our policies and procedures.
        • The free Charity Excellence downloadable policies include provision for both AI and tech such as crypto.

AI Web Scraping

We have included AI scraping of our website data in our risk assessment. Where we do not wish our site pages to be scraped, we have taken steps to minimise the risk of this, whilst recognising that such action may not be respected by AI companies.  This might include:

  • Using meta tags such as 'NoAI' or 'NoImageAI'.
  • Amending our website Terms & Conditions (T&Cs).

Meta Tags.  The use of meta tags, such as those above, has been floated by various companies and agencies but is not an industry standard and there's no guarantee that all, of even any, bots will comply.

T&Cs.  Our lay person's understanding of web scraping is that it might be considered illegal if the necessary amount of creative input was not used to create whatever the data scraped was used for, which might amount to copyright infringement.  We also understand that it is possible to restrict the re-use of scraped data through your T&Cs.  That is, if a company accesses your website and consents to your T&Cs, which contain a restriction on the re-use of the data, if they then do so they may be in breach of contract.

Designing Charity AI - Principles

We design and build our own AI systems with pro bono support from expert AI companies.  We have used our learning to create a separate resource that should be read in conjunction with this one.  It provides a simple set of AI design principles for those designing or commissioning AI systems.

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Other AI Governance and Ethics Resources

The Charity AI Ethics & Governance Framework was informed by the work of others, including:

This Charity AI Governance and Ethics Framework Is Not Professional Advice

This charity AI Governance and Ethics Framework is for general interest only and does not constitute professional legal or financial advice.  I'm neither a lawyer, nor an accountant, so not able to provide this, and I cannot write guidance that covers every charity or eventuality.  I have included links to relevant regulatory guidance, which you must check to ensure that whatever you create reflects correctly your charity’s needs and your obligations.  In using this resource, you accept that I have no responsibility whatsoever from any harm, loss or other detriment that may arise from your use of my work.  If you need professional advice, you must seek this from someone else. To do so, register, then login and use the Help Finder directory to find pro bono support. Everything is free.

Ethics Note: AI was used in the initial draft of this framework.  All of our work is subject to human oversight and checking before being published. .  This work was last updated Feb 25.

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