Applying ethical principles to innovation
The purpose of this framework is to help government communicators assess whether their use of emerging technologies and data is in line with our values and ethical standards.
The framework provides a structured, three-step approach to identify ethical considerations from the outset of any innovative work, guiding decision-making using Civil Service and Government Communications values.
- Step 1: Consider legal obligations
- Step 2: Consider propriety guidance
- Step 3: Review relevant policies and guidance
This framework is regularly reviewed and updated to reflect emerging opportunities, risks and official guidance.
For more complex innovation projects, a separate assessment guide is available. This guide can help with stakeholder mapping and includes a template assessment grid to record findings when reviewing ethical considerations.
Understand our core values
British values
Democracy, the rule of law and human rights are the foundations of our society, and important principles to consider in our work. For example, democratic accountability means we should always act in a transparent manner, and be able to fully explain or justify an approach or how a decision was made to our ministers.
Considering human rights in our work includes any impact on the fundamental entitlements and freedoms for all. For example, not impinging on individual liberties through adoption of new technologies. These values are especially important when it comes to our use of generative AI.
Civil Service Code
As a Civil Service profession, we are required to follow the Civil Service Code, which means we must act with integrity, honesty, objectivity and impartially in all our work. For example, honesty is essential for maintaining trust in democratic institutions, and we strengthen this through communicating our actions transparently.
Guiding principles of Government Communication
Government communications must follow four guiding principles as set out in our propriety and ethics guidance: relevance to government responsibilities, objectivity without bias, non-partisan communication and appropriate use of public funds. These principles are especially important when using emerging technologies like generative AI, where communicators must prioritise accuracy, inclusivity and bias mitigation to maintain public trust.
Step 1: Consider legal obligations
Your planned activity or approach should comply with existing laws and regulations.
UK Data Protection Act
- Data processing: Personal data should only be collected and used where there is a clear legal justification, and that this can be communicated clearly to data subjects as necessary.
- Impact assessments: Data Protection Impact Assessments (DPIAs) should be carried out for any new or large-scale data processing, or use of sensitive data to identify and mitigate risks.
- Information Commissioner’s Office (ICO): Any data breaches must be reported to the ICO within 72 hours.
UK General Data Protection Regulation
- Data processing: Individuals must consent to their data being processed; you should obtain explicit opt-in consent before collecting or sharing information.
- Data rights and transparency: Individuals have the right to transparency on who accesses their data, why it was collected and how it is used; you must be able to provide disclosure when required.
- Data transfers: Consider if any data will be transferred outside of the UK, and if you have the appropriate safeguards in place to mitigate risks associated with this.
Equality Act 2010
- Inclusivity and representation: Activity should respect inclusivity and equal representation, and we should not perpetuate biases or stereotypes in our work.
- Accessibility: We should consider how our work can be made as accessible as possible to people with disabilities. This means providing information in accessible formats, such as large print, and ensuring digital content meets accessibility standards wherever possible.
Intellectual Property Act
- Trademarks: Trademark protection would need to be considered in the use of any official insignia, logos or service marks.
- Patents: Any patented processes or technologies being used in the creation or dissemination of communications would need to comply with patent laws.
- Copyrights: The UK government often has a permitted right to use copyrighted material for official purposes under ‘Crown Use’ provisions.
This is not an exhaustive list. There may be other specific laws, acts or regulations to consider which may be relevant to your organisation. Read more on legal considerations in the AI Playbook for the UK Government.
Step 2: Consider propriety guidance
Uphold the Civil Service Code
Will you be able to uphold the Civil Service Code through your planned activity? For example, but not exclusively:
- Will your planned activity prevent you from making decisions that are solely based on evidence, and without favouritism?
- Will you be able to act in a transparent manner about your planned activity? For example, will you be able to fully explain or justify an approach or how a decision was made to your minister?
- Will your planned activity uphold political neutrality, avoiding involvement in partisan politics and maintaining a focus on serving the government of the day?
- Will you be able to explain your planned activity? For example, ensuring the relevant people can access, interpret and understand your activity? Read more about transparency and explainability in the AI Playbook for the UK Government.
Remember to consider:
- Integrity: Putting the obligations of public service above personal interests.
- Honesty: Being truthful and open.
- Impartiality: Basing advice and decisions on rigorous analysis of the evidence.
- Objectivity: Acting solely according to the merits of the case and serving governments of different political parties equally well.
Follow propriety and ethics guidance
The Government Communications propriety and ethics guidance sets out four guiding principles we should apply in our work.
- Government communications should be relevant to government responsibilities
- Government communications should be objective and explanatory, not biased or polemical
- Government communications should not be – or liable to be – misrepresented as being party-political
- Government communications should be conducted in an economic and appropriate way and should be able to justify the costs as expenditure of public funds
Will you be able to uphold these through your planned activity?
Relevant
The communication should be relevant to government responsibilities.
Matters dealt with by government publicity should be ones in which the government has direct and substantial responsibilities. The government should explain and justify its policies and decisions, and, when necessary, inform, advise, alert or warn the public.
Will your planned activity be relevant to government responsibilities and free from party political biases?
Not party-political
The communication should not be – or liable to be – misrepresented as being party-political.
It must not justify or defend policies in party-political terms, use political slogans, advocate policies of a particular political party or directly attack policies and opinions of opposition parties or groups.
Will your communications clearly explain the government-of-the-day policies’ in a balanced and objective way, whilst serving the best interests of the public?
Objective and explanatory
The communication should be objective and explanatory, not biased or polemical.
Government communications should be as objective as possible; personalisation of issues and biases should be avoided and any communications should always come from a perspective of informing the public.
Through your planned activity, will you be accurate and truthful, ensuring that all information presented to the public is reliable and factually accurate?
Read our propriety and ethics guidance for areas which may not be covered in this framework, but are relevant to your planned activity.
Economic and appropriate
The communication should be conducted in an economic and appropriate way and should be able to justify the costs as expenditure of public funds.
The use of public funds should be appropriate and effective in their application. The resources should be justifiable on value-for-money grounds.
Does any expenditure represent value for money for taxpayers by delivering an outcome which serves the public good in the most economical way?
Step 3: Review relevant polices and guidance
You should review other relevant policies and guidance relating to your planned activity – some common examples are provided below.
Activity 1: I’m planning to use a new channel or platform
Read the SAFER framework for guidance on digital brand safety.
The 5 SAFER principles are:
- Safety
- Appropriate environments
- Freedom of speech
- Ethics
- Risks and responsibilities
Activity 2: I’m planning a new or different use of first-party data
Follow these 3 steps using the Government Communications Innovating with Impact Strategy:
- Map and discover
- Secure consent and communicate
- Minimise and innovate
Activity 3: I’m planning the use of generative AI
Before using generative AI, read the Government Communications Generative AI policy and confirm how it applies to your planned activity.
- How we will use generative AI.
- How we will not use generative AI.
- How we will act transparently in our use.
Additional considerations for complex projects
For complex innovation projects, follow the guidance below.
Activity: I’m planning the development of a new AI tool
Review the AI Playbook for the UK Government and consider the following principles when developing your tool.
- Security of AI tools: Sensitive information should be safely handled and in line with data-protection legislation.
- Meaningful human control: Processes should be in place to ensure that AI outputs are checked and validated by qualified personnel.
- Lifecycle management: From selection to decommissioning, the lifecycle of AI tools must be managed carefully.
- Choosing the right tool: Selecting the most suitable AI technology for the task at hand is vital to ensure effectiveness and cost-efficiency.
- Openness and collaboration: Engaging widely with other departments and stakeholders is encouraged to foster transparency and innovation.
- Integration with commercial practices: Collaboration with commercial partners should maintain high standards of transparency and ethical practice.
- Skills and expertise: Building and maintaining AI tools requires specific skills, which should be developed within an organisation.
- Compliance and assurance: AI use should align with existing organisational policies and governance structures.
Activity: I’m planning a new or different use of first-party data
Read the GOV.UK Data and AI Ethics Framework and apply the following principles to your planned data use.
- Value and public benefit: Data use should be clearly linked to public good, ensuring that the benefits of any data initiative are maximised for the public while respecting the rights and interests of individuals.
- Clarity and transparency: Activities involving data should be understandable and transparent to the public. The reasons for decisions and the methodologies used should be open and accessible.
- Accountability and responsibility: Those working with data should remain accountable for their actions. This involves clear documentation of decisions and ensuring responsibility for data use is always attributed.
- Ethical practices and governance: Data use should comply with ethical standards and legal requirements, with clear governance structures in place to guide decision-making and oversee the responsible use of data.
- Equity and fairness: Individuals and communities should be treated fairly, with measures to avoid and address biases, discrimination and the unintended consequences of data use. Data must be used in ways that strive to be inclusive and equitable.
Activity: I’m planning to develop or adopt a new data model or digital tool in my work
Review the Responsible Tech Adoption Unit (RTA) Principles for Responsible Innovation and consider the following principles.
- Stay updated on evolving legal and ethical requirements and adapt technology accordingly
- Regularly conduct audits and assessments to verify compliance where this is legally required, and identify areas for improvement
- Collect feedback from users, stakeholders and relevant experts to identify areas for improvement and address ethical concerns
- Continuously adapt and enhance the technology and its supporting processes to align with evolving ethical standards and societal expectations
- Establish mechanisms for reporting and addressing ethical concerns or dilemmas related to the technology’s use
- Provide accessible information about data-handling practices, algorithms and decision-making processes to promote transparency and informed decision-making
- Clearly communicate to users and stakeholders how the technology works, its intended purpose and any potential risks or limitations, if needed
- Take responsibility for any errors or biases in the technology and establish mechanisms for redress and rectification
You should also refer to the Algorithmic Transparency Recording Standard (ATRS)
- Transparency and accessibility: Information about the use of algorithmic tools must be openly published in an understandable and easily accessible way via an algorithmic transparency report. This should include details about how these tools support any decision-making processes.
- Comprehensive information: Detailed documentation should include descriptions of the tool’s design, operation, the decision-making processes it influences, the data it uses, any associated risks and measures taken to mitigate these risks.
- Clear assignment of responsibilities: Where appropriate, organisations are required to designate specific roles such as an Algorithmic Transparency Lead, who oversees the completion of transparency records. This role involves coordinating with various departments to gather necessary information and ensure compliance with the standard.
- Inclusion of all relevant stakeholders: The process of completing a transparency record involves contributions from various sectors of an organisation, including operational teams, data science teams, legal and ethics departments, ensuring a holistic representation of how algorithmic tools are used.
Framework in action: Case study 1
Opportunity
AI tools to enable the automated hiding of comments below an advertiser’s posts on social media platforms.
Potential benefits for government communications
- Time saved moderating comment sections
- Reducing the exposure to harmful language for those engaging with government social content
- Minimising the impact of harmful language on campaign messaging
Issues identified through applying this framework
- The technology may transfer data across different international regions, raising data-protection risks with inadvertent sharing of personal data
- By hiding comments made by the public, use of the technology may impact upon principles of the Human Rights Act, specifically impinging upon individual’s Freedom of Expression
Result
In the form offered, this technology is not currently suitable for use in government communication. Further research is required to identify whether there are specific applications which would justify the additional spend on this type of tool, over simply turning off comments on posts.
Framework in action: Case study 2
Opportunity
AI-powered tools for assessing diversity in digital communications content, in order to identify opportunities for improvement.
Potential benefits for government communications
Support efforts to ensure government communications are representative of the audiences we are trying to reach and represent.
Issues identified through applying this framework
For the tool offered, the underlying AI technology is trained on demographic data from the United States, which may not be fully representative of the unique demographic landscape of the UK.
Result
The technology is not yet mature enough to avoid perpetuating bias in its results within a UK context, and so not yet suitable for use in government communications.
What should you do next?
If you have identified that there are barriers preventing you from upholding either our legal obligations, propriety guidance or best practices and policies, you should:
- Pause activity for now
- Carefully review the risks or barriers you have identified, and consider where further scrutiny or attention is required to uphold or abide by these before proceeding
- Engage with experts in the area where further attention is required to strengthen your approach, or identify other innovative means to achieve your objectives
- If your planned activity involves the application of AI, our Generative AI policy outlines additional relevant guidance. You should also review the AI Playbook for the UK Government.
- Once ready, reassess your planned activity using this framework
If you have reviewed all relevant steps for your planned activity, and identified the risks to be low, then it’s now over to you for the final step – to test and scale!
We encourage you to continuously evaluate your activity against this framework, and continually engage with experts and peers to help you.
Contact the Government Communication Service team (AI.GCS@cabinetoffice.gov.uk) if you:
- Have feedback about how we can improve this framework
- Need more guidance on identifying, testing and scaling innovative ideas
- Want to know more about good practice in insight and evaluation
- Want to know more about best practice in data modelling and visualisation
- Want to know how to lead effective campaigns using data
Government Communications members can also find fellow professionals with relevant skills on Connect, our member platform, and connect with peers in our community forums to share experiences, discuss challenges and learn from others working on similar projects. Sign in to Connect.