Why this policy exists
SPRING Family recognizes the importance of clear guidelines for the responsible and effective use of AI. This policy promotes ethical AI practices, protects data, ensures transparency and mitigates potential risks associated with non-generative and generative AI across the group. It is designed to foster innovation while prioritizing the well-being of clients, employees and stakeholders.
Definitions
Non-generative AI refers to systems designed to perform specific, predefined tasks within a limited scope, such as image recognition, recommendation systems and speech recognition. Generative AI involves models capable of generating new content or data, including text, art, music, and speech or video synthesis.
Scope and applicability
The policy covers all ongoing and future AI projects, internal and external, carried out on behalf of the organization. It extends to solutions developed in-house and solutions integrated through partnerships with external vendors or third-party providers.
Approval process and risk-based approach
Every AI solution developed, procured or used by the organization requires a risk assessment by SPRING Group IT and SPRING Group Compliance, with responsible people assigned for testing and documenting use cases. Assessments consider data privacy, security, integration, legal compliance, transparency, public knowledge and supplier evaluation.
Risk categories
Low and minimal risk solutions can be used by all employees under existing rules. Limited-risk solutions can be used under generic company rules and application guidelines. High-risk solutions require pre-approved employees and a specific code of conduct. Unacceptable-risk solutions are prohibited.
Data security and usage
We never share client-owned material to public training pools or external repositories. Client data is handled confidentially, access is limited to authorized personnel, and clients are informed upfront before AI usage. Production or commercial output is screened and approved case by case where required.
AI implementation process
Employees follow a standardized process: pre-investigation of the AI solution, initial risk assessment, production test, compliance review, IT review, and final risk assessment or evaluation.
AI Steering Committee
A group-wide Steering Committee made up of SPRING Group IT, Compliance and relevant business-unit stakeholders maintains the AI Code of Conduct and AI Policies. It supports responsible implementation, transparent client dialogue and prompt action where business-critical legal or ethical matters arise.