Module 2 of 2 · 45 minutes
Honest appeals, donor data and people working in your name
By the end of this module you will be able to
- Apply the transparency test to AI content
- Carry out the human check before content is used
- Protect donor data when using a tool
- Keep chatbots and automated tools under review
- Hold agencies and partners to the same standard
Work through it
1 interactive for this module, built on the WAJD Teach engine. Nothing moves until you ask it to, and every one has a written version if you would rather read it.
Watch: Emma and George talk it through
3 minutes. Captions are on, and the same conversation is written out in full below. The voices are computer generated.
Emma George, our appeal needs a photo and we don't have one. The tool can generate a child at a food bank. Can we use it?
George Think about what a donor would believe. The guidance gives a sliding rule. The amount of transparency should be in proportion to the risk of misleading donors. The greater the risk, the more transparent you should be.
Emma And a generated child?
George High risk. A donor will take it as someone you helped. If the person, the picture or the words were generated, they mustn't be left believing otherwise.
Emma What about AI tidying the grammar of a true appeal?
George No label needed. Nobody's misled about anything.
Emma Who checks the appeal before it goes?
George A person. The guidance says have a process for a human to check the accuracy, fairness and legality of any content generated by AI before using it.
Emma Break those down.
George Accuracy. Are the figures and the claims about impact true? Fairness. Is it respectful, without undue pressure? Legality. Does it meet the Code, data protection law and the advertising rules?
Emma We'd like the tool to pick which donors to ask for more.
George Then you're using personal data. The guidance says at all times know how any AI tool will use, store and share the material you put into it.
Emma Use, store, share.
George Three verbs. If you can't answer them, the supporter list doesn't go in. And your privacy information should say how AI is involved.
Emma Some of our donors are elderly.
George The Code's section on people in vulnerable circumstances applies to a tool that chooses whom to ask, how often and for how much. Exactly as it would to a person making those choices.
Emma We also have a chatbot on the donation page.
George Where there's no immediate human oversight, the guidance says have measures to monitor and audit it. It speaks for the charity.
Emma And our telephone fundraising agency?
George Same accountability. Review the agreement, ask how they use AI on your behalf, and monitor it. You answer for what's done in your name.
The written material
How transparent to be
The guidance gives a sliding rule. The amount of transparency you provide should be in proportion to the risk of misleading donors. The greater the risk of misleading donors through or about your use of AI, the more transparent you should be.
So a tool that tidied the grammar of a true appeal needs no label. A generated photograph of a child who does not exist, used as though it showed someone the charity helped, carries a high risk of misleading and needs to be made clear. The guidance draws particular attention to AI generated images, video and sound.
A person checks before it goes out
The guidance says to make sure you have a process in place for a human to check the accuracy, fairness and legality of any content generated by AI before using it.
Accuracy: are the figures, the need and the claims about impact true? Fairness: does it treat the people shown, and the people asked, with respect, without pressure or stereotype? Legality: does it meet the Code, data protection law and the rules on advertising?
- Accuracy: is every claim true?
- Fairness: is it respectful, without undue pressure?
- Legality: does it meet the Code and the law?
Donor data
The guidance says that at all times you should make sure you know how any AI tool will use, store and share the material you use to train and prompt it. A list of donors, their giving history and notes about them is personal data, and some of it may reveal health, belief or financial difficulty.
Your privacy information should say how AI is involved in processing people's data. And the Code's section on fundraising involving people in vulnerable circumstances applies to a tool that selects whom to ask, how often and for how much, exactly as it does to a person making those choices.
Chatbots, and others acting for you
Where there is no immediate human oversight, as with an online chatbot, the guidance says it is important to have measures in place to monitor and audit the use. A chatbot that answers questions about donations speaks for the charity.
The same accountability covers agencies, professional fundraisers and commercial partners. Review your agreements with them, ask how they use AI on your behalf, and monitor it. The guidance points to the regulator's guides on due diligence and on monitoring fundraising partners.
Knowledge check
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