Incorporate moral principles into a data strategy and AI policy

The ethical principles that shape an organisation should be formalised and incorporated into a policy or strategy. LOTI suggests having two separate documents:

1. A Corporate Data Strategy. This should detail the data priorities of the organisation as a whole, and define the ethical principles detailed in Capability 1, and the steps the council is planning to take to act on these principles over the defined period of time. Given the foundational aspect of data in AI, this strategy could be expanded to include AI – however, as AI adoption goes much further than data most councils may choose to avoid having a distinct ‘AI strategy’. LOTI has forthcoming guidance on creating a Data Strategy. 
2. AI Policy for Staff. This policy should be something to guide potential ‘AI users’ in an organisation to ensure that they are using AI ethically. It should describe the actions that they take when using AI which are in line with the principles that the council has adopted.

Historically, LOTI suggested that councils adopt relevant ethics considerations into their a single data strategy. However, the emergence of AI caused LOTI to reflect on whether this is appropriate. We now believe that there is a place for a specific organisational AI policy, which should be distinct but attached to a data policy or strategy. This is because:

• There are some unique AI capabilities that prove unique challenges: for example, sharing data in free online tools, how to prompt generative AI models, how to understand the outputs of generative AI,
• There will be new AI capabilities which could require a council to respond in a more agile way than updating an existing data strategy or creating a new one in a few years.
• Every officer in a council could now theoretically be using AI, whereas historically councils could guess and manage what data tools most officers would be using;

LOTI recommends that any policies and strategies are designed to be as practical as possible and that they focus on action (i.e. aligning organisational deliverables with the principles).

By detailing the actions that their organisation will take, councils set themselves up to do ethical assurance much easier in the future. This is because they have already described the actions that would fulfil the moral principles, so assuming the actions are good, the council just needs to evaluate if they are doing those actions.

Recommendation 2 in practice

Camden’s Data Charter includes a set of commitments that the Council promises to deliver with different time frames and that are informed by the seven principles of the charter. This includes, for example, creating a Data Sharing Register to publish all data sharing agreements, or giving the right Officers the tools and responsibilities to handle data ethics within their organisation.

On top of this, Camden are also accountable to their residents via a follow up Resident Panel, to ensure that they meet the goals set out by residents.

< Identify shared moral principles that reflect your organisation’s and residents’ values.

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