1. Purpose of this Policy
This policy sets out how artificial intelligence (AI) tools may be used across Walden
Capital in a way that is ethical, lawful, transparent, and aligned with existing GDPR,
Privacy, and Data Protection obligations.
The intention is not to restrict innovation, but to ensure AI is used responsibly, with
clear accountability and appropriate safeguards.
2. Scope
This policy applies to: – All employees, contractors, consultants, and freelancers working
on behalf of Walden Capital – All departments, including (but not limited to) marketing,
content, research, operations, finance, and leadership – All AI-powered tools, platforms,
and features, whether standalone or embedded in third-party software
3. What We Mean by AI
For the purposes of this policy, AI includes: – Generative AI tools (e.g. text, image,
video, or code generation) – AI-assisted analytics and forecasting tools – AI-powered
marketing, personalisation, or automation tools – Embedded AI features within SaaS
platforms
4. Permitted Use of AI
AI tools may be used to: – Support drafting, summarising, or structuring content – Assist
with research, ideation, or data interpretation – Improve efficiency in administrative or
operational tasks – Support data analysis where lawful, anonymised, and compliant
All AI-generated outputs must be reviewed by a human before use, publication, or
decision-making.
5. Prohibited and Restricted Use
AI tools must not be used to: – Process personal data unless explicitly approved and
compliant with GDPR – Upload confidential, proprietary, or client-identifiable information
into public AI tools – Make automated decisions with legal, financial, or material impact
without human oversight – Generate misleading, deceptive, or non-transparent content –
Circumvent consent mechanisms, tracking restrictions, or privacy controls
6. Data Protection, GDPR, and Privacy Alignment
AI use must align with Walden Capital’s existing: – GDPR policy – Privacy Policy – Data
Protection and Information Security policies
Key principles that continue to apply: – Lawfulness, fairness, and transparency –
Purpose limitation – Data minimisation – Accuracy – Storage limitation – Integrity and
confidentiality
Where AI tools are used: – Personal data must be anonymised or pseudonymised
wherever possible – Data must not be retained or reused by AI providers unless
contractually agreed – International data transfers must be assessed and documented
7. Consent, Tracking, and Website AI
Walden Capital’s website now uses: – Google Tag Manager (GTM) – Google Tag
Gateway (GTG) – Configured consent mechanisms with best practice privacy
configurations.
8. Transparency and Disclosure
Where AI materially contributes to: – Published content – Research outputs – Marketing
materials
Walden Capital may choose to disclose AI assistance where appropriate, particularly if it
affects interpretation or trust.
AI should not be presented as human expertise.
9. Accountability and Oversight
- Responsibility for AI use remains with the individual and the company, not the
tool
Managers are responsible for ensuring their teams comply with this policy
Any risks, incidents, or concerns related to AI use must be reported promptly- Â
10. Training and Awareness
Walden Capital will: – Provide guidance on responsible AI use – Update this policy as
regulation and best practice evolves – Review AI use alongside GDPR and privacy
audits
11. Review and Related Policy Updates (Important)
This AI Use Policy highlights areas that may require updates or cross-referencing within
existing compliance documents:
Privacy Policy: Explicit reference to AI-assisted processing, analytics, and
personalisation
GDPR Documentation: Clarification on AI tools as processors or sub-
processors
Cookie Policy: Alignment with AI-driven analytics and consent logic via GTM/GTG
Third-Party Vendor Register: Inclusion of AI-enabled tools and platforms
12. Status
This document is a working draft and should be reviewed regularly as: – AI capabilities
evolve – Regulations (including UK GDPR and EU AI Act considerations) develop –
Walden Capital’s operational use of AI expands