At Croud, we believe Artificial Intelligence has the potential to transform marketing by enabling our people to work smarter, innovate faster and deliver greater value for our clients.
We also recognise that AI introduces new legal, ethical and operational considerations. Responsible governance is therefore fundamental to how we adopt and deploy AI across our business.
A responsible AI Framework allows us to continue to deliver best in class work for our clients whilst establishing clear boundaries so that we are considered in our use. This is our responsibility not only to our clients, but also the amazing human talent we have.
Human-Centred: AI enhances our people's expertise - it does not replace professional judgement or accountability. All material client work remains subject to appropriate human review.
Secure by Design: We protect client and company information by ensuring AI technologies are assessed for security, privacy and data protection before adoption.
Transparent: We are open with our clients about how AI supports our work and respect contractual and legal disclosure commitments relating to AI usage.
Ethical: We use AI responsibly, avoiding applications and use cases that could create discriminatory or harmful outcomes. Where appropriate, we test for and mitigate against algorithmic bias.
Accountable: Responsibility for decisions always remains with Croud people - not AI systems.
Commercially Responsible: We adopt AI where it improves quality, efficiency, and value while maintaining appropriate governance and controls.
Croud has established a cross-functional AI Governance Committee responsible for overseeing the safe, ethical and effective adoption of AI across the business, which meets monthly.
The committee brings together representatives from: Legal, Compliance, Information Security, Technology and Operations.
Responsibilities include:
With AI evolving rapidly, our governance framework is therefore reviewed regularly to ensure it reflects emerging risks, industry best practice as well as technological developments.
Regulatory Landscape
We comply with applicable AI, data protection and advertising laws in each market in which we operate, including the UK, EU, US and UAE.
Croud actively monitors and complies with developing AI regulation across the markets in which it operates, including the EU AI Act and the UK's principles-based approach to AI regulation. The AI Governance Committee is responsible for conducting regulatory horizon scanning and updating this Framework to reflect new and evolving regulatory requirements. Where applicable, Croud will assess its AI use cases against relevant regulatory classifications and take appropriate steps to ensure ongoing compliance.
How We Assess AI Technologies
Every new AI tool is assessed against a consistent governance framework before approval. Criteria include:
Only approved technologies may be used for business purposes. Approvals are subject to reassessment where a tool materially changes its terms.
We maintain appropriate controls to protect confidential information, including:
We do not permit confidential client information to be entered into unapproved AI platforms. Client data will never be used to train public or third-party models without explicit, written consent.
We do not use AI to make decisions based solely on automated processing, including profiling, that produce legal or similarly significant effects on individuals, unless a lawful basis and appropriate safeguards (including human review) are in place.
All Croud personnel must observe the following prohibited uses when working with AI technologies. The following activities are strictly prohibited:
Any breach of these acceptable use requirements will be treated as a serious matter and may result in disciplinary action.
All use of AI in connection with client work must comply with the relevant client contract, including any terms relating to AI usage, confidentiality and sub-processor obligations. Where required under a client contract, Croud shall obtain client consent or provide notification prior to using AI in the delivery of services.
Members of the Croud freelancer network (Croudies) are bound by equivalent AI usage and confidentiality obligations to those applicable to Croud employees.
We recognise that ownership of AI-generated content continues to evolve. Accordingly:
AI supports decision making but it does not replace professional judgement. Our people remain accountable for all outputs, including but not limited to:
We provide training to staff on the importance of these principles and what that means in practice for them day to day.
Croud provides mandatory, periodic training on responsible AI use and this Framework to all staff. This training ensures that the principles set out in this Framework are understood and consistently applied in practice across all areas of the business.