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During this week’s Research Assistant Peer Call we continued our discussion around the use of artificial intelligence (AI) in collections. When it comes to governing this new technology it’s important to realize our policy statements on AI may change frequently as we gain a better understanding of how we can use this to streamline processes and where we need to mitigate risks.
From our conversation we identified the following elements that should be in a robust Artificial Intelligence Acceptable Use Policy (AUP):
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Purpose and Scope: Clearly define the purpose of the AUP and specify its applicability to all employees, contractors, and third-party users who may interact with AI systems within the organization.
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Compliance with Laws and Regulations: Emphasize compliance with relevant laws, regulations, and industry standards governing AI technology, data protection, privacy, and financial services.
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Ethical Use of AI: Establish principles for the ethical use of AI, including fairness, transparency, accountability, and non-discrimination. Ensure that AI systems do not perpetuate bias or unfair practices.
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Data Privacy and Security: Outline protocols for safeguarding sensitive financial and personal data used by AI systems. Specify encryption methods, access controls, and data retention policies to protect against unauthorized access and data breaches.
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Transparency: Require that AI systems used provide transparency into their operations and outputs. Ensure that users can understand how AI algorithms make decisions and provide explanations when necessary.
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Risk Management: Address the risks associated with AI deployment, such as model risk, operational risk, and systemic risk. Implement processes for identifying, assessing, and mitigating these risks.
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Customer Consent and Notification: Establish procedures for obtaining informed consent from customers when AI technologies are used to negotiate or set-up payments. (i.e. interactive AI communication tools)
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Employee Training and Awareness: Require role-specific training to educate employees about AI technologies, their capabilities, limitations, and ethical considerations. Promote awareness of potential biases and risks associated with AI use.
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Monitoring and Compliance: Implement mechanisms for monitoring AI systems to ensure compliance with the AUP and applicable regulations. Conduct regular audits and reviews of AI algorithms, data sources, and decision-making processes.
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Accountability and Oversight: Designate roles and responsibilities for overseeing AI initiatives within the organization. Hold individuals and teams accountable for adhering to the AUP and ethical guidelines.
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Third-party Vendors and Partnerships: Extend the AUP to cover third-party vendors and partners who provide AI solutions or services to the organization. Require adherence to ethical standards and data security protocols.
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Incident Response and Reporting: Establish procedures for reporting AI-related incidents, such as data breaches, algorithmic errors, or unethical behavior. Implement a response plan to address incidents promptly and mitigate potential harm.
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Continuous Improvement: Commit to ongoing evaluation and improvement of AI governance practices. Solicit feedback from stakeholders, monitor emerging trends in AI ethics, and update the AUP as needed to reflect evolving best practices.
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Consequences of Non-compliance: Clearly communicate the consequences of violating the AUP.
We will continue to seek out feedback and best practices within our Research Assistant Peer community to stay on top of all the moving pieces of this new technology.
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