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FREMAP acknowledges the relevance of using Artificial Intelligence (AI) to achieve its objectives as an entity collaborating with the Social Security pursuant to section 80 et seq. of the recast text of the General Social Security Act, noting the benefits it can bring especially in terms of process efficiency and automation. AI is to be used responsibly and ethically, thus minimising any risks which may result from its application. Likewise, AI will be used in accordance with the principles of service, respect, equality, transparency and social responsibility as set out in FREMAP's Code of Conduct. AI may never be used in FREMAP for the commission of a criminal offence, whether directly or indirectly.
FREMAP's Artificial Intelligence (AI) Use Policy has been drawn up pursuant to European regulations and, in particular, to Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024 laying down harmonised rules on artificial intelligence and amending Regulations (EC) No 300/2008, (EU) No 167/2013, (EU) No 168/2013, (EU) 2018/858, (EU) 2018/1139 and (EU) 2019/2144 and Directives 2014/90/EU, (EU) 2016/797 and (EU) 2020/1828 (Artificial Intelligence Act).
The commitments and guidelines set out in this policy are to be observed in all use, deployment, alteration and development of artificial intelligence initiatives and systems by FREMAP employees and members of FREMAP's governance and participation bodies.
It will also apply to external professionals or suppliers associated with FREMAP by means of a works or services agreement under the clauses included in their agreements.
This policy will come into force on the day following its approval by the CEO and will be notified to all employees in a memo which will be posted on the entity's website. It will also be reported to the members of the entity's participation bodies.
FREMAP will make sure that all employees and members of governance and participation bodies have the training needed to use AI responsibly in accordance with applicable legislation, FREMAP's internal regulations and this policy.
The following principles will govern the use of AI in the entity:
- Respect for fundamental rights and human supervision. When using, deploying and developing AI, the individual will always be considered, respecting fundamental rights and human dignity, and human supervision mechanisms will be adopted to ensure this. Particular attention should be paid to diversity, non-discrimination and equity in monitoring and mitigating discriminatory bias.
- Regulatory compliance and use. AI is to be used in accordance with current AI legislation and in strict compliance with this policy and the entity's internal rules. The practices listed for this purpose in applicable regulations and any others which do not comply with this policy are banned. Privacy management and personal data processing will also have to be adopted in compliance with applicable regulations. In general, the use of any AI system that has not been expressly authorised by the entity following a risk analysis is banned.
- Technical security. FREMAP will ensure that its systems are secure, reliable, robust and resistant to cyber-attacks, thereby enhancing their overall security.
- Transparency. This policy safeguards transparency in the information used and ensures that the use of AI optimises our operations in all areas in the interest of efficient service. The highest levels of transparency and explainability are to be maintained with respect to people involved in the deployment of AI systems, reporting on interaction with such systems, documenting decisions taken, and any other circumstances. This will prevent any opacity in processes which might lead to criminal and administrative liability.
- System audits. Our systems are regularly audited and have the necessary mechanisms in place to minimise any problems. Specific audits of AI systems will ensure they are used responsibly and diligently. Likewise, the results generated will be regularly reviewed and supervised to identify any failures or malfunctions which may pose a compliance risk for FREMAP.
- Third-party rights. FREMAP warrants respect for the rights of third parties (intellectual and industrial property) in cases where generative AI is used.
- Staff training and awareness-raising. FREMAP will ensure diligent and responsible use of AI together with the application of best practice in its use, making sure that all staff understand the implications, risks and benefits of AI.