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You are an AI Ethics & Compliance Officer working for the user's organisation. Your role is to walk them through setting up responsible, ethical AI governance from scratch — or auditing what they already have. The user has uploaded an HTML file (the ManchesterHumans Ethical AI Toolkit) containing 10 compliance document templates. You MUST read and reference the actual templates from that file when helping the user. Each template contains specific fields, tables, and checklists — use those exact structures when generating filled-in documents. PERSONALITY: - Warm, practical, and direct. British English. - No jargon unless you explain it. No waffle. - Think of yourself as a helpful colleague, not a regulator. - Be encouraging — ethical AI is achievable, not overwhelming. YOUR TOOLKIT — 10 DOCUMENTS (from the uploaded file): You will help the user create or review these 10 documents. Reference them by name. Use the exact template structure from the uploaded HTML file when generating filled-in versions. 1. AI POLICY — The organisation's overarching AI governance policy. Covers purpose, scope, principles, roles, accountability, and review cycle. 2. AI REGISTER — An inventory of every AI system in use. Logs name, purpose, data inputs, risk level, owner, deployment status, and review date. 3. RISK REGISTER — AI-specific risk assessment. Each risk has an ID, description, likelihood (1-5), impact (1-5), risk score, mitigations, owner, and review date. 4. USE CASE WORKSHEET — Per-project evaluation completed before deploying any AI system. Covers business need, data sources, affected stakeholders, fairness checks, human oversight plan, and sign-off. 5. BIAS AUDIT CHECKLIST — Step-by-step checklist for identifying and mitigating bias in training data, model outputs, and deployment context. 6. MODEL CARD — Documentation for each AI model: capabilities, limitations, training data, intended use, out-of-scope use, ethical considerations, and performance metrics. 7. IMPACT ASSESSMENT — Evaluates social, economic, and environmental impact before deployment. Covers affected groups, potential harms, benefits, and mitigation plans. 8. TRANSPARENCY PROTOCOL — How to communicate AI usage to users, regulators, and communities. Covers disclosure requirements, plain-language explanations, and opt-out mechanisms. 9. DATA GOVERNANCE PLAYBOOK — Data collection, consent, anonymisation, retention, access controls, and GDPR/regulatory alignment. 10. AI INCIDENT RESPONSE PLAN — What to do when AI goes wrong. Covers detection, escalation, containment, communication, root cause analysis, and prevention. WORKFLOW: 1. Start by asking what the user's organisation does, roughly how many people work there, and whether they currently use any AI systems. 2. Based on their answer, assess their current maturity level (Starting Out / In Progress / Advanced) and tell them. 3. Walk through each document ONE AT A TIME. For each: a. Explain what it is and why they need it (2-3 sentences) b. Ask the specific questions needed to fill it in c. When you have enough info, generate the completed document in a clean, copy-pasteable format d. Ask if they want to revise anything before moving on 4. After all documents, provide a summary of: - Their overall compliance posture - Top 3 priority actions - Recommended review schedule 5. Offer to deep-dive into any specific area they're concerned about. RULES: - Always ask ONE question at a time. Never overwhelm with multiple questions. - If the user seems unsure, give them sensible defaults they can adopt (e.g., "Most organisations your size review quarterly — shall we go with that?") - Flag genuine risks clearly but without being alarmist. - If something is legally specific (GDPR fines, sector regulations), note that they should verify with legal counsel. - Generate documents in clean markdown format with tables where appropriate. - The user can skip any document — that's fine, note it and move on. - If they already have a document, offer to review it rather than creating from scratch. IMPORTANT CONTEXT: - This toolkit is provided free by ManchesterHumans (manchesterhumans.com) - It's designed to be practical and actionable, not theoretical - It aligns with the EU AI Act, UK AI governance framework, and GDPR - For complex enterprise needs, recommend contacting [email protected] Start by introducing yourself warmly, explaining what you'll help them do, and asking your first question.
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Version: [1.0] | Effective Date: [DD/MM/YYYY] | Review Date: [DD/MM/YYYY] | Owner: [Name, Role]
This policy establishes the principles, governance structure, and accountability framework for the development, procurement, and deployment of Artificial Intelligence systems at [Organisation Name].
This policy applies to all AI and automated decision-making systems used by [Organisation Name], including but not limited to: machine learning models, large language models, robotic process automation, recommendation engines, and any system that makes or assists decisions affecting individuals or operations.
| Role | Responsibility | Named Individual |
|---|---|---|
| AI Governance Lead | Owns this policy, chairs review meetings, escalation point | [Name] |
| System Owner | Responsible for each AI system's compliance and performance | [Per system] |
| Data Protection Officer | Ensures AI data processing complies with GDPR | [Name] |
| Senior Leadership | Approves high-risk AI deployments, allocates resources | [Name/Team] |
| Risk Level | Description | Approval Required |
|---|---|---|
| Low | Internal tools, no decisions affecting individuals | System Owner |
| Medium | Customer-facing, assists decisions but human makes final call | AI Governance Lead |
| High | Autonomous decisions affecting individuals' rights, safety, or finances | Senior Leadership + DPO |
All new AI systems (built or bought) must complete a Use Case Worksheet and Impact Assessment before deployment. Third-party AI vendors must demonstrate compliance with this policy's principles.
This policy is reviewed [quarterly / biannually / annually]. The AI Register is reviewed monthly. Incident reports trigger immediate review of relevant sections.
Non-compliance with this policy should be reported to [AI Governance Lead / reporting channel]. Breaches will be investigated and may result in system suspension, disciplinary action, or regulatory notification as appropriate.
Approved by: [Name, Title] | Date: [DD/MM/YYYY]
Last Updated: [DD/MM/YYYY] | Maintained by: [Name, Role]
| ID | System Name | Purpose | Type | Data Inputs | Risk Level | Owner | Status | Last Reviewed |
|---|---|---|---|---|---|---|---|---|
| AI-001 | [e.g. Customer Chatbot] | [e.g. Handle tier-1 support queries] | [LLM / ML / RPA] | [Customer messages, order history] | [Low / Medium / High] | [Name] | [Active / Pilot / Retired] | [DD/MM/YYYY] |
| AI-002 | [System name] | [Purpose] | [Type] | [Data] | [Risk] | [Owner] | [Status] | [Date] |
| AI-003 | [System name] | [Purpose] | [Type] | [Data] | [Risk] | [Owner] | [Status] | [Date] |
Last Updated: [DD/MM/YYYY] | Owner: [Name, Role]
| Risk ID | AI System | Risk Description | Likelihood (1-5) | Impact (1-5) | Score | Mitigations | Owner | Review Date |
|---|---|---|---|---|---|---|---|---|
| R-001 | [AI-001] | [e.g. Chatbot provides incorrect medical advice] | [3] | [5] | [15] | [Disclaimer, human escalation trigger, topic blocklist] | [Name] | [Date] |
| R-002 | [AI-001] | [e.g. Biased responses to certain demographics] | [2] | [4] | [8] | [Quarterly bias audit, diverse test sets] | [Name] | [Date] |
| R-003 | [System] | [Risk] | [L] | [I] | [S] | [Mitigations] | [Owner] | [Date] |
| Impact 1 | Impact 2 | Impact 3 | Impact 4 | Impact 5 | |
|---|---|---|---|---|---|
| Likelihood 5 | 5 | 10 | 15 | 20 | 25 |
| Likelihood 4 | 4 | 8 | 12 | 16 | 20 |
| Likelihood 3 | 3 | 6 | 9 | 12 | 15 |
| Likelihood 2 | 2 | 4 | 6 | 8 | 10 |
| Likelihood 1 | 1 | 2 | 3 | 4 | 5 |
Green (1-6): Accept & monitor | Amber (7-14): Mitigate & review quarterly | Red (15-25): Urgent action required, escalate to senior leadership
System Name: [Name] | Date: [DD/MM/YYYY] | Author: [Name, Role]
[What problem does this AI solve? Why can't it be solved without AI? What's the expected benefit?]
| Question | Answer |
|---|---|
| What type of AI is this? | [LLM / ML classifier / recommendation engine / RPA / other] |
| Is it built in-house or third-party? | [In-house / Vendor name / Open source] |
| What decisions does it make or assist? | [Describe] |
| Who are the end users? | [Staff / Customers / Public] |
| Question | Answer |
|---|---|
| What data does it use as input? | [Describe data sources] |
| Does it process personal data? | [Yes / No — if yes, complete DPIA] |
| Is a lawful basis for processing established? | [Consent / Legitimate interest / Contract / etc.] |
| Where is data stored and processed? | [UK / EU / US / other] |
| Check | Status |
|---|---|
| Could this system affect different groups differently? | [Yes / No — if yes, describe] |
| Has the training data been checked for demographic bias? | [Yes / No / N/A] |
| Has the system been tested with diverse inputs? | [Yes / No] |
| Is there a plan for ongoing bias monitoring? | [Describe] |
| Question | Answer |
|---|---|
| Is there a human in the loop for decisions? | [Always / For edge cases / Never] |
| Can a human override the AI's output? | [Yes / No] |
| Who is the named human responsible? | [Name, Role] |
| What's the escalation process? | [Describe] |
Risk Level: [Low / Medium / High]
Justification: [Why this risk level?]
Added to Risk Register? [Yes / No — must be Yes for Medium/High]
| Role | Name | Approved? | Date |
|---|---|---|---|
| System Owner | [Name] | [Yes/No] | [Date] |
| AI Governance Lead | [Name] | [Yes/No] | [Date] |
| DPO (if personal data) | [Name] | [Yes/No] | [Date] |
System: [AI System Name] | Auditor: [Name] | Date: [DD/MM/YYYY]
| # | Check | Status | Notes |
|---|---|---|---|
| A1 | Data sources documented and reviewed | [ ] | |
| A2 | Demographic representation analysed | [ ] | |
| A3 | Under-represented groups identified | [ ] | |
| A4 | Historical bias in source data assessed | [ ] | |
| A5 | Data labelling process reviewed for bias | [ ] | |
| A6 | Synthetic data or re-sampling used if needed | [ ] |
| # | Check | Status | Notes |
|---|---|---|---|
| B1 | Outputs tested across demographic groups | [ ] | |
| B2 | Performance metrics disaggregated by group | [ ] | |
| B3 | Error rates compared across groups | [ ] | |
| B4 | Edge cases and adversarial inputs tested | [ ] | |
| B5 | Confidence thresholds reviewed | [ ] |
| # | Check | Status | Notes |
|---|---|---|---|
| C1 | Affected populations identified | [ ] | |
| C2 | Feedback mechanism exists for affected users | [ ] | |
| C3 | Human override available for contested decisions | [ ] | |
| C4 | Monitoring plan for post-deployment bias drift | [ ] | |
| C5 | Re-audit schedule established | [ ] |
Result: [Pass / Pass with conditions / Fail]
Required Actions: [List any actions needed before deployment or continued operation]
Next Audit Date: [DD/MM/YYYY]
Version: [v1.0] | Date: [DD/MM/YYYY] | Owner: [Name]
| Field | Details |
|---|---|
| Model Type | [LLM / Classifier / Regressor / etc.] |
| Architecture | [e.g. Transformer, GPT-4, Fine-tuned BERT] |
| Provider | [In-house / OpenAI / Anthropic / etc.] |
| Training Data | [Describe sources, size, date range] |
| Fine-tuning Data | [If applicable — describe custom training data] |
[What is this model meant to do? What tasks? What users?]
[What should this model NOT be used for? List explicitly.]
| Metric | Value | Evaluated On |
|---|---|---|
| [Accuracy / F1 / BLEU / etc.] | [Value] | [Dataset] |
| [Metric] | [Value] | [Dataset] |
Assessor: [Name] | Date: [DD/MM/YYYY]
| Group | How Affected | Severity |
|---|---|---|
| [e.g. Customers] | [Describe impact] | [Low / Medium / High] |
| [e.g. Employees] | [Describe impact] | [Low / Medium / High] |
| [e.g. Vulnerable populations] | [Describe impact] | [Low / Medium / High] |
| Harm | Who's Affected | Likelihood | Severity | Mitigation |
|---|---|---|---|---|
| [e.g. Incorrect advice] | [Users] | [Medium] | [High] | [Human review, disclaimers] |
| [e.g. Job displacement] | [Staff] | [Low] | [Medium] | [Retraining programme] |
| Factor | Assessment |
|---|---|
| Energy consumption of training/inference | [Estimate or "uses third-party API"] |
| Data centre location & energy source | [If known] |
| Net environmental effect | [Positive / Neutral / Negative] |
Proceed with deployment? [Yes / Yes with conditions / No]
Conditions: [List any required actions]
Review date: [DD/MM/YYYY]
Version: [1.0] | Date: [DD/MM/YYYY]
| Scenario | Disclosure Required | Method |
|---|---|---|
| AI generates content shown to users | Yes | [e.g. "This response was generated with AI assistance" label] |
| AI assists human decision-making | Yes | [e.g. "An AI system flagged this for review" note] |
| AI makes fully automated decisions | Yes (GDPR Art. 22) | [e.g. Notification + right to request human review] |
| AI used in internal processes only | To staff | [e.g. Internal AI register accessible to all staff] |
For each AI system, maintain a plain-language explanation accessible to non-technical users:
| AI System | Opt-Out Available? | How to Opt Out | Alternative Provided |
|---|---|---|---|
| [System name] | [Yes / No / Partial] | [Method] | [What happens instead] |
Regulatory bodies notified: [ICO / sector regulator / none required]
AI Act registration: [Required / Not required / Completed]
Public AI usage statement: [URL or "to be published"]
Version: [1.0] | DPO: [Name] | Date: [DD/MM/YYYY]
| Principle | Implementation |
|---|---|
| Purpose limitation | [Data collected only for specified, explicit purposes] |
| Data minimisation | [Only collect what's necessary for the stated purpose] |
| Lawful basis | [Document lawful basis for each data processing activity] |
| Technique | Used For | Implementation |
|---|---|---|
| Pseudonymisation | [e.g. Customer records in training data] | [Method used] |
| Anonymisation | [e.g. Analytics aggregation] | [Method used] |
| Differential privacy | [e.g. Model training] | [Method used] |
| Data Type | Retention Period | Deletion Method | Responsible |
|---|---|---|---|
| [e.g. Training data] | [e.g. 2 years] | [Secure deletion] | [Name] |
| [e.g. User queries] | [e.g. 30 days] | [Auto-purge] | [Name] |
Process for handling: Access requests (SAR) | Rectification | Erasure | Portability | Objection to automated processing
Response time target: [Within 30 days per GDPR]
Contact: [DPO email / privacy portal URL]
Version: [1.0] | Owner: [Name] | Date: [DD/MM/YYYY]
| Level | Description | Response Time | Escalation |
|---|---|---|---|
| Low | Minor error, no external impact, easily corrected | 24 hours | System Owner |
| Medium | User-facing error, potential reputational impact, limited harm | 4 hours | AI Governance Lead |
| High | Significant harm to individuals, regulatory breach, data breach | 1 hour | Senior Leadership + DPO + Legal |
| Critical | Ongoing harm, safety risk, regulatory investigation | Immediate | CEO + Legal + Regulator |
| Role | Name | Contact |
|---|---|---|
| AI Governance Lead | [Name] | [Phone / Email] |
| Data Protection Officer | [Name] | [Phone / Email] |
| Senior Leadership | [Name] | [Phone / Email] |
| Legal | [Name] | [Phone / Email] |
| Communications | [Name] | [Phone / Email] |
| ICO (if data breach) | Information Commissioner's Office | 0303 123 1113 / ico.org.uk |
| Date | System | Severity | Description | Actions Taken | Status |
|---|---|---|---|---|---|
| [Date] | [System] | [Level] | [What happened] | [What was done] | [Open/Closed] |
This plan should be tested via tabletop exercise [annually / biannually]. Last test: [Date]. Next test: [Date].
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