I. Purpose
This policy establishes a comprehensive, yet flexible, governance structure for AI systems used by, or on behalf of, Keenfunnel LLC. This policy enables Keenfunnel LLC to use AI systems for the benefit of its customers, employees, and stakeholders while safeguarding against potential harms.
The key objectives of the AI Policy are to:
- Provide guidance that is clear, easy to follow, and supports decision-making for the staff (full-time, part-time), interns, consultants, contractors, partners, and volunteers who may be purchasing, configuring, developing, operating, or maintaining Keenfunnel LLC’s AI systems or leveraging AI systems to provide services to Keenfunnel LLC.
- Ensure that when using AI systems, Keenfunnel LLC or those operating on its behalf, adhere to the Guiding Principles that represent values with regards to how AI systems are purchased, configured, developed, operated, or maintained.
- Define roles and responsibilities related to usage of AI systems by Keenfunnel LLC.
- Establish and maintain processes to assess and manage risks presented by AI systems used by Keenfunnel LLC.
- Align AI governance with existing data, security, and privacy policies and guidelines.
- Define prohibited uses of AI systems.
- Establish “sunset” procedures to safely retire AI systems that no longer meet the needs of Keenfunnel LLC.
- Define how AI systems may be used for legitimate purposes in accordance with applicable local, state, and federal laws.
“Artificial intelligence” or “AI” is defined to be a machine-based system that can, for a given set of human-defined objectives, make predictions, recommendations, or decisions influencing real or virtual environments. AI systems use machine and human based inputs to perceive real and virtual environments; abstract such perceptions into models through analysis in an automated manner; and use model inference to formulate options for information or action.
An “AI system” is defined to be any data system, software, hardware, application, tool, or utility that operates in whole or in part using AI.
AI systems and the data contained therein will be purchased, configured, developed, operated, and maintained in line with existing data, security, and privacy policies and guidelines.
II. Scope
This policy applies to:
- All AI systems deployed by Keenfunnel LLC; and
- Staff (full-time, part-time), interns, consultants, contractors, partners, and volunteers who may be purchasing, configuring, developing, operating, or maintaining Keenfunnel LLC's AI systems or who may be leveraging AI systems to provide services to Keenfunnel LLC.
III. Guiding Principles
These principles describe Keenfunnel LLC's values with regards to how AI systems are purchased, configured, developed, operated, or maintained.
- Human-Centered Design: AI systems are developed and deployed with a human-centered approach that evaluates AI powered services for their impact on our customers, employees, and stakeholders.
- Security & Safety: AI systems maintain confidentiality, integrity, and availability through safeguards that prevent unauthorized access and use. Implementation of AI systems is reliable and safe, and minimizes risks to our customers, employees, and stakeholders.
- Privacy: Privacy is preserved in all AI systems by safeguarding personally identifiable information (PII) and sensitive data from unauthorized access, disclosure, and manipulation.
- Transparency: The purpose and use of AI systems is proactively communicated and disclosed to our customers, employees, and stakeholders. An AI system, its data sources, operational model, and policies that govern its use are understandable and documented.
- Equity: AI systems support equitable outcomes for everyone. Bias in AI systems is effectively managed with the intention of reducing harm for anyone impacted by its use.
- Accountability: Roles and responsibilities govern the deployment and maintenance of AI systems, and human oversight ensures adherence to relevant laws and regulations.
- Effectiveness: AI systems are reliable, meet their objectives, and deliver precise and dependable outcomes for the utility and contexts in which they are deployed.
- Workforce Empowerment: AI systems are reliable, meet their objectives, and deliver precise and dependable outcomes for the utility and contexts in which they are deployed.
IV. Roles & Responsibilities
Several roles are responsible for enforcing this policy, outlined below.
Key personnel responsible for enforcing this policy include the Chief Information Officer, Chief Information Security Officer, Chief Artificial Intelligence Officer, and other relevant departments.
- The Chief Information Officer is responsible for directing Keenfunnel LLC technology resources, policies, projects, services, and coordinating with other departments. The Chief Information Officer shall designate the Chief Information Security Officer to actively ensure AI systems are used in accordance with existing data, security, and privacy policies and guidelines. The Chief Information Officer shall also designate the Chief Artificial Intelligence Officer to actively ensure the AI system is used in accordance with this policy and other relevant policies and guidelines.
- The Chief Information Security Officer is responsible for overseeing the enterprise security infrastructure, cybersecurity operations, updating security policies, procedures, standards, guidelines, and monitoring policy compliance.
- The Chief Artificial Intelligence Officer is responsible for overseeing the enterprise digital privacy practices, data processing practices, and responsible usage of technology in compliance with data and privacy policies and guidelines. The Chief Artificial Intelligence Officer is responsible overseeing the privacy practices of AI systems used by or on behalf of Keenfunnel LLC departments.
- Keenfunnel LLC departments departments are responsible for following this policy and following updates to this policy and other relevant policies and guidelines.
- The Chief Information Officer shall notify Keenfunnel LLC departments when an update to this policy or other relevant policies and guidelines is released.
- The Legal Department is responsible for advising of any legal issues or risks associated with AI systems usage by or on behalf of Keenfunnel LLC departments.
- The Executive Office may, at its discretion, inspect the usage of AI systems and require a department to alter or cease its usage of AI systems or a partner’s usage of AI systems on behalf of the department.
- The Finance Department is responsible for overseeing the procurement of AI systems and requiring vendors to comply with Keenfunnel LLC policy standards through contractual agreements.
V. Policy
When purchasing, configuring, developing, operating, or maintaining AI systems, Keenfunnel LLC will:
- Uphold the Guiding Principles for Responsible AI Systems;
- Conduct an AI Review to assess the potential risk of AI systems. The Chief Artificial Intelligence Officer is responsible for coordinating review of AI systems used by Keenfunnel LLC;
- Obtain technical documentation about AI systems or create documentation if internally developing the AI system;
- Require contractors to comply with the requirements for AI Systems overseen by the Finance Department; and
- In the event of an incident involving the use of the AI system, Keenfunnel LLC will follow a incident response plan as maintained by the Chief Information Security Officer. The Chief Information Security Officer is responsible for overseeing the security of AI systems used by or on behalf of Keenfunnel LLC departments.
If Keenfunnel LLC staff become aware of an instance where an AI system has caused harm, staff must report the instance to their supervisor and the Chief Artificial Intelligence Officer.
Sunset Procedures
If an AI system operated by Keenfunnel LLC or on its behalf ceases to provide a positive utility to Keenfunnel LLC our customers, employees, or stakeholders as determined by the Chief Artificial Intelligence Officer, then the use of that AI system must be halted unless express exception is provided by the Chief Information Officer or Executive Office. If the abrupt cessation of the use of that AI system would significantly disrupt the delivery of Keenfunnel LLC services, usage of the AI system shall be gradually phased out over time.
Policy Enforcement
All employees and agents of Keenfunnel LLC, whether permanent or temporary, interns, volunteers, contractors, consultants, vendors, and other third parties operating AI systems on behalf of Keenfunnel LLC are required to comply with this policy and other relevant policies and guidelines.
VI. Violations of the AI Policy
Violations of any section of the AI Policy, including failure to comply with this policy and other relevant policies and guidelines may be subject to disciplinary action, up to and including termination. Violations made by a third party while operating an AI system on behalf of Keenfunnel LLC may result in a breach of contract and/or pursuit of damages. Infractions that violate local, state, federal or international law may be remanded to the proper authorities.
VII. Terms & Definitions
Artificial Intelligence: “Artificial intelligence” or “AI” to be a machine-based system that can, for a given set of human-defined objectives, make predictions, recommendations, or decisions influencing real or virtual environments. Artificial intelligence systems use machine- and human-based inputs to perceive real and virtual environments; abstract such perceptions into models through analysis in an automated manner; and use model inference to formulate options for information or action.
Algorithm: A series of logical steps through which an agent (typically a computer or software program) turns particular inputs into particular outputs.
AI System: Any system, software, sensor, or process that automatically generates outputs including, but not limited to, predictions, recommendations, or decisions that augment or replace human decision-making. This extends to software, hardware, algorithms, and data generated by these systems, used to automate large-scale processes or analyze large data sets.