Contents
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1.1 Policy Statement
The purpose of this document (hereinafter – the Policy) is to provide Bud Financial Limited’s (hereinafter “Company”, “Bud”) Clients and Client’s employees with clear guidelines for the use of Drive CoPilot and the content generated by them. It aims to ensure that Drive CoPilot is used responsibly, ethically, and in compliance with applicable AI laws and other applicable regulations, including Consumer Duty.
1.2 Why does Bud need this Policy?
Bud is going to provide Drive CoPilot services across the United Kingdom. Therefore, Bud is obligated to adhere to the relevant regulations and this Policy outlines our approach to ensure compliance.
1.3 Relevant Regulation
AI regulation: a pro-innovation approach in the United Kingdom. While the regulations are still being finalised, we are already adhering to their principles and will fully comply once they are in force.
1.4 Scope
This Policy applies to all individuals affiliated with Bud's Clients, including permanent employees, temporary workers, contractors, and any other engaged parties (hereinafter - “Client’s employees”) using Bud CoPilot.
1.5 General Provision
a. Drive CoPilot is created specifically for financial institutions to get the outcomes of the analysis of specific customer data, eliminating the need for extensive manual labour. Use case: Drive CoPilot could be used by a financial institution’s employee to identify individuals who have recently applied for a mortgage, enabling them to connect with these customers and propose complementary products, like home insurance.
b. Our Drive CoPilot Fair Use Policy guidelines are based on the following principles:
2.1 Make sure that your end-user is informed and agrees about Drive CoPilot processing their information;
2.2 Disclose to your end-users the specific types of data that the Drive CoPilot chatbot will be processing and make sure the end-user agrees to share such data with Drive CoPilot;
2.3 Ensure your end-users understand how their data is being used by Drive CoPilot;
2.4 Client employees are responsible for being able to explain how their decisions were made based on end-user data assessments provided by Drive CoPilot.
3.1 Client employees can ask Drive CoPilot for an explanation of the logic it has used to provide an answer, while Bud maintains the confidentiality of its proprietary AI algorithms and trading strategies;
4.1 Please be informed that, for audit purposes, we may request you to provide us with data on the inquiries made to Drive CoPilot by your company's employees, along with the corresponding outcomes.
4.2 Please be advised that you may be requested to provide us with your Company's AI statement, along with any relevant policies or procedures related to AI governance and risk mitigation, for the purposes of due diligence;
4.3 Please be advised that your Company's employees will have the option in the chat to send Bud their feedback on Drive CoPilot Chatbot performance.
5.1 Bud will perform regular audits on AI decisions and questions raised by Clients’ employees, as well as analyse any feedback provided by the Client, to perfect Drive CoPilot and its ethics and efficacy;
5.2 Bud will ensure Drive CoPilot will be compliant with all applicable future AI laws and regulations, as well as Consumer Duty regulations.
6.1 Client has to implement strict access management to ensure that only authorised employees can access the Drive CoPilot;
6.2 Client has to ensure robust access management - only employees who have a purpose to use Drive CoPilot should have access, not any Client employee;
6.3 Client has to ensure that only relevant departments can ask specific types of questions, for example: only the Leasing team can inquire Drive CoPilot about the leasing-related data of your end-users;
6.4 Client has to ensure their employees do not include personal information in the Drive CoPilot chat as the conversations may be stored and used for research or training purposes;
6.5 Before granting access to Drive CoPilot, the Client must provide detailed instructions to all employees who have access to it to ensure their compliance with this fair use policy.
7.1 High standards of information security will be applied to the Drive CoPilot’s systems;
8.1.When utilizing Drive CoPilot to recommend suitable lending options for end-users, it is crucial to ensure that the proposed products align with the end-user's affordability and circumstances. Only services or recommendations that the client is genuinely capable of affording should be presented;
8.2 Maintain strict adherence to data privacy requirements and refrain from providing Drive CoPilot with sensitive personal information, such as race, ethnicity, religious beliefs, political affiliations, or sexual orientation of end-users;
8.3 Report any identified risk incidents involving Drive CoPilot, including instances of disturbing or inaccurate responses, to us for review and resolution (refer to 12.2 for the reporting procedure)
8.4 Clients must allow their end-users to challenge decisions made with Drive CoPilot’s assistance. Bud must be notified when an end user challenges a decision and that challenge is justified (refer to 12.2 for the reporting procedure);
8.5 Client has to implement a review process for decisions made after consulting with Drive CoPilot to ensure the accuracy, consistency, and appropriateness of the AI-generated recommendations or responses. Bud must be notified when this review flags any areas for improvement (refer to 12.2 for the reporting procedure);
9.1 Bud has established and regularly updates a comprehensive "Banned Questions" (see the list in Section 11 of this Policy) list database to prevent the Drive CoPilot from answering inappropriate or harmful questions;
9.2 Bud is analyzing risk incidents reported to us by our clients involving the CoPilot, particularly instances where it provides inaccurate responses. These incidents are systematically reviewed to extract valuable lessons and enhance the Drive CoPilot's performance.
Client’s employees will be able to ask Drive CoPilot questions such as the following (this list is not exhaustive):
10.1 Did your answer take into account XYZ?
10.2 Were there any assumptions made to answer this question?
10.3 Can you explain how you got to this conclusion or answer?
10.4 Can you show me the data and information you considered to answer this question?
10.5 I would like to provide you with feedback about your last answer as it may not be accurate.
10.6 Send feedback to Bud about an answer the AI chatbot provided to me recently.
Client’s employees should avoid asking Drive CoPilot the following questions (and if detected Drive CoPilot may not provide answers to them):
11. 1 Questions pertaining to political campaigns.
11.2Questions pertaining to religious organisations or religion.
11.3 Questions pertaining to therapy for mental health.
11.4 Questions pertaining to sexual orientation (LGBTQ+).
11.5 Questions pertaining to customers who are immigrants or race.
11.6 Questions pertaining to customers who have disabilities.
11.7 Questions that promote hate speech or discrimination.
11.8 Questions that involve illegal activities or solicit illegal advice.
11.9 Questions that promote violence or harm to oneself or others.
11.10 Questions that invade personal privacy or violate someone's rights.
11.11 Questions that are designed to harass, threaten or intimidate.
11.12 Questions that contain profanity or explicit language.
11.13Questions that are sexually explicit or offensive.
11.14 Questions that are discriminatory based on race, gender, sexuality or religion.
11.15 Questions that solicit financial or investment advice.
12.1 Bud periodically reviews and updates this Policy as needed to ensure that it remains effective and complies with applicable laws and regulations.
12.2The Client shall immediately notify Bud by emailing lrc@thisisbud.com in case Bud’s AI has led to a poor customer outcome as a result of either incorrect information, misrepresentation, misinformation, not being transparent, not being fair or any other reason where Bud needs to train our AI models to exclude such behavior.
12.3 The Client shall maintain an easily accessible complaints process for the end consumer to report complaints (specifically when an outcome or decision was made as a result of using Bud’s AI).
This policy is not to be amended without the permission of the General Counsel and VP Risk and Compliance . Please note, policies may be revised from time to time.
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