AI Compliance & Responsible Use

1. Our Approach to Responsible AI

First Page Digital provides AI-enabled services designed to help businesses respond to enquiries, communicate with customers, qualify leads, manage appointments and automate routine customer interactions.

Depending on the service activated, this may include:

• AI Chat;
• AI Voice;
• enquiry handling;
• lead qualification;
• appointment assistance;
• customer communication;
• conversation summarisation; and
• workflow assistance.

Our approach is based on several core principles:

• transparency;
• appropriate data use;
• data minimisation;
• security;
• human oversight where appropriate;
• clear purpose;
• respect for individual privacy rights; and
• compliance with applicable laws.

AI should support legitimate business processes rather than mislead people about who or what they are interacting with.

2. AI Transparency

Where an AI system interacts directly with an individual and disclosure is required, the person should be informed that they are interacting with an AI system.

Our AI agents are configured to provide appropriate transparency at the beginning of an interaction or at another appropriate point depending on the context and technology being used.

AI agents must not intentionally impersonate a human or mislead an individual into believing they are communicating with a human where this is not the case.

This approach supports applicable transparency requirements, including relevant requirements under the EU AI Act where applicable.

3. AI Voice and Call Recording

AI Voice systems may need to process audio in real time in order to understand and respond to callers.

Depending on the configuration, conversations may also be recorded or transcribed. Where recording or transcription is enabled, appropriate notice should be provided where required.

The organisation deploying the AI Voice service must determine the appropriate lawful basis and notification requirements for its particular use case and jurisdiction.

Where GDPR applies, processing of personal data must have an appropriate lawful basis. Depending on the circumstances, that lawful basis may differ between deployments.

Where New Zealand privacy law applies, organisations should ensure that collection of personal information through recording or transcription is transparent, lawful and fair in the circumstances.

First Page Digital configures AI Voice deployments to support appropriate disclosure and privacy practices.

4. AI Chat

AI Chat Agents may interact with website visitors or customers through websites, messaging channels or other supported communication channels.

Where appropriate, users should be informed that they are communicating with an AI assistant.

AI Chat Agents should:

• operate within their defined business purpose;
• collect only information reasonably required for that purpose;
• avoid requesting unnecessary sensitive information;
• clearly communicate when they cannot appropriately handle a request;
• provide escalation to a human or alternative contact route where appropriate; and
• avoid intentionally misleading users.

5. Data Protection and Privacy

Use of AI does not remove existing privacy and data-protection responsibilities.

Personal information processed through AI services must be handled in accordance with applicable privacy and data-protection law.

Our approach includes:

Data Minimisation

AI services should only request and process information reasonably necessary for the intended purpose.

Purpose Limitation

Information collected through an AI interaction should be used for defined and legitimate purposes.

Transparency

Individuals should receive appropriate information about relevant processing where required.

Security

Appropriate technical and organisational safeguards should be applied to AI-related personal information.

Retention

Recordings, transcripts and other AI-related information should not be retained indefinitely without an appropriate purpose. Retention requirements may vary depending on the client, service, purpose and applicable law.

6. Our AI Technology

AI-enabled functionality supplied through First Page Digital's Ignite services is delivered through the HighLevel platform.

HighLevel provides the platform through which relevant AI functionality is configured and delivered.

HighLevel may use authorised downstream technology providers to provide components such as:

• conversational AI;
• language processing;
• speech recognition;
• speech generation;
• transcription;
• model inference; and
• related AI infrastructure.

For current information about relevant processing providers, refer to the First Page Digital Master Sub-Processor List.

7. Client Data and AI Model Training

First Page Digital does not intentionally use client customer conversations to train public AI models for First Page Digital's own purposes.

Where AI functionality relies on third-party technology supplied through HighLevel, the handling of data is subject to the relevant contractual, privacy and data-processing arrangements applying to those services.

We select and configure services with the objective of protecting client information and limiting processing to the purposes required to provide the relevant service.

8. Human Oversight and Escalation

AI systems are intended to assist with defined business processes and should not be treated as universally appropriate replacements for human judgement.

Where appropriate, AI workflows may include mechanisms to:

• transfer or escalate an enquiry;
• request human assistance;
• arrange a callback;
• flag conversations requiring attention; or
• stop automation where the AI cannot appropriately handle the request.

Clients should determine when human review is appropriate for their particular business and use case.

9. Automated Decision-Making

AI may be used to assist with activities such as enquiry classification, lead qualification or routing.

First Page Digital does not design standard Ignite AI services to make solely automated decisions that produce legal or similarly significant effects on individuals.

Where a client proposes using AI for decisions that could significantly affect an individual, additional assessment, safeguards and legal review may be required before deployment.

10. Outbound AI Communications

AI must not be used to bypass applicable direct-marketing, privacy or communications laws.

For outbound AI calls, messages or other communications, the client is responsible for ensuring that it has an appropriate legal basis and any consent required for the communication.

Outbound AI communications must comply with the marketing, privacy and communications laws applicable to the recipient, communication channel and jurisdiction. For example, marketing calls to mobile phones in Ireland are subject to specific ePrivacy requirements.

First Page Digital may restrict or refuse AI deployments that appear likely to involve unlawful unsolicited communications.

11. Client Responsibilities

Clients using First Page Digital AI services remain responsible for how AI is deployed within their business.

Clients are expected to:

• provide accurate information and instructions used by AI agents;
• maintain an appropriate Privacy Policy;
• provide appropriate AI and recording notices where required;
• establish an appropriate lawful basis for processing personal information;
• comply with applicable marketing and communications rules;
• ensure customer information supplied to the system has been lawfully obtained;
• avoid using AI for unlawful, deceptive, discriminatory or harmful purposes;
• review AI behaviour and outputs where appropriate;
• maintain appropriate human oversight;
• notify First Page Digital of material changes to the intended AI use case; and
• comply with the applicable First Page Digital Service Agreement and Master Data Processing Agreement.

12. First Page Digital's Role

The legal role of First Page Digital depends on the processing involved.

Where First Page Digital processes customer information through an AI service on behalf of a client, the client will generally determine the purpose of the processing and act as the Data Controller or responsible agency.

First Page Digital will generally act as the Data Processor or service provider for that processing. Our respective responsibilities are further addressed in the First Page Digital Master Data Processing Agreement.

Where First Page Digital processes information for its own business purposes, our role may be different. See our Privacy Policy for further information.

13. Ireland and European Union

For relevant deployments in Ireland and the European Union, AI services may be subject to requirements arising from:

• the General Data Protection Regulation (GDPR);
• applicable ePrivacy rules;
• the EU AI Act; and
• other applicable consumer, communications and data-protection laws.

The exact requirements depend on the particular AI system, purpose and deployment. First Page Digital does not claim that every AI system has the same regulatory classification.

14. New Zealand

For relevant deployments in New Zealand, personal information processed through AI services must be handled consistently with applicable New Zealand privacy requirements, including the Privacy Act 2020 and relevant Information Privacy Principles.

Where AI Voice calls are recorded or transcribed, appropriate notification should be provided where required.

Clients remain responsible for ensuring that their particular use of AI complies with applicable New Zealand law.

15. Responsible Use

First Page Digital may decline, restrict, suspend or require changes to an AI deployment where we reasonably believe it:

• breaches applicable law;
• materially infringes individual privacy;
• is intentionally deceptive;
• involves unlawful unsolicited communications;
• creates an unacceptable security risk;
• is being used outside its agreed purpose; or
• otherwise presents a material compliance risk.

16. Our Compliance Framework

This page should be read together with the relevant First Page Digital legal and privacy documents, including:

• Privacy Policy;
• Cookie Policy;
• applicable Service Agreement;
• Master Data Processing Agreement; and
• Master Sub-Processor List.

17. Contact Us

For questions about First Page Digital's approach to AI, privacy or data processing, contact:

Email: [email protected]

Website: firstpagedigital.ie