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AI Use Policy

Digitom Ltd (“the Company” / “We”) use AI tools to support parts of our creative and production process in simple, low-risk ways. This policy explains how and why we use generative AI, what we will not use it for, and how we protect client privacy. Our aim is to work responsibly, stay aligned with our values, and use technology in a way that supports positive social and environmental impact.

Co-Founders and Company Directors Tom Chown & Roz Chown are both responsible for ensuring this AI use policy is implemented, however all employees, contractors and freelancers have a responsibility in their area to ensure that the aims and objectives of this policy are met.

1. Scope

The terms “artificial intelligence” and “AI” are not currently defined in the areas of UK law that generally apply to the use of Generative AI.

AI is defined as:

“technology enabling the programming or training of a device or software to:

  • perceive environments through the use of data
  • interpret data using automated processing designed to approximate cognitive abilities
  • make recommendations, predictions or decisions; with a view to achieving a specific objective”

Generative AI currently has no separate legal definition, however is broadly defined as a type of AI which creates text, images, audio, video, or programming code in response to prompts input by users. Generative AI is not directly regulated itself in the UK, but other legal areas including intellectual property law and data protection law intersect with it.

The Company is committed not only to the relevant laws, but also to ensuring that Generative AI is used in a way which minimises the risks relating to intellectual property, data protection and discrimination, and aligns with our Company values. Generative AI must be used by directors, employees, contractors, or anyone working on behalf of the Company with care and due diligence at all times and in accordance with this policy.

The Company believes that the innovative use of Generative AI has the potential to be of great value to the Company and its clients. The directors of the Company are responsible for administering this policy and ensuring that all employees, contractors, or anyone working on behalf of the Company (“users”) comply with this policy.

2. Principles

The following general principles should be kept in mind at all times when using Generative AI:

Responsibility: Users of Generative AI tools are ultimately responsible for their use and for the outputs generated by such tools.

Lawfulness: Generative AI should always be used in compliance with applicable laws including, but not limited to, data protection law and intellectual property law.

Confidentiality and privacy: Generative AI must always be used in a manner which protects and preserves the confidentiality and privacy of data.

Impartiality: Where Generative AI is being used to generate outputs in which there is a risk of bias, appropriate steps must be taken to identify and mitigate such bias.

Clarity and transparency: The application and output of Generative AI should be clear and understandable by users and by clients.

3. Data protection and privacy

Data protection law in the UK consists of a range of legislation applying to data protection and privacy and includes the UK GDPR, the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations 2003. The terms “AI” “artificial intelligence” are not currently defined in data protection law; however, all personal data will be managed in accordance with the Company’s Privacy Policy.

Our Privacy Policy applies to all uses of personal data within, for, and on behalf of the Company. It sets out the Company’s obligations regarding the collection, processing, transfer, storage, and disposal of personal data.

The Company handles client information with care. We avoid uploading identifiable or sensitive materials — such as contributor interviews, scripts, rushes, briefs, internal documents or strategic information — to AI systems. Where referencing content is necessary, we will anonymise, redact or summarise details. We use temporary or non‑stored AI sessions for low‑risk tasks and delete inputs immediately after use. If a tool’s data practices are unclear or if it adds input data to its training data, we will not use it.

4. Confidentiality

“Confidential information” is defined by the Company as any information designated by the Company as confidential, and any other information as follows:

  • any and all confidential or proprietary information relating to:
    • the Company’s business, customers, clients, or suppliers;
    • the Company’s operations, processes, product information, trade secrets, know-how, or technical information; and
    • further information, data, analysis, or findings derived from such Confidential Information.

The definition of confidential information set out above shall also apply to information of that nature which is received from third parties and designated as confidential (for example, confidential information which is subject to a non-disclosure agreement, which may also incorporate further restrictions on the use of such information).

We will not normally use confidential information in conjunction with a Generative AI tool, but if it is deemed necessary in order to fulfil a client contract, we will adhere to any specific policies or the terms of any specific contracts (e.g., non-disclosure agreements) which apply to that confidential information. If any such policy or contract prohibits the use of the confidential information in such a manner, it will not and must not be used in conjunction with Generative AI.

Users will and must ensure they fully understand how the Generative AI tool uses data inputs before inputting any confidential information. If the Generative AI tool adds input data to its training data and/or shares that data with third parties, confidential information must not and will not be used in conjunction with that Generative AI tool.

5. Intellectual property

In the context of this Policy, the term “intellectual property rights” means patents, rights to inventions, copyright and related rights, moral rights, trade marks, business names, domain names, rights in get-up and trade dress, goodwill and the right to passing off actions, design rights, database rights, rights to use confidential information and the right to protect the same, and any and all other intellectual property rights, whether registered or unregistered, including applications and the right to apply for (and be granted) renewals or extensions of, and rights to claim priority from, any such rights and any and all equivalent rights or other forms of protection subsisting now or in the future anywhere in the world.

Generative AI tools may be used to create a wide range of works in which intellectual property rights subsist. Similarly, its training data may incorporate many different kinds of works protected by intellectual property rights and, in particular, copyright.

Outputs produced by Generative AI will be reviewed and checked by the Company for compliance with any and all applicable licences. The ownership of intellectual property rights in the outputs produced by Generative AI may vary from one Generative AI tool to another and users must ensure that they read, understand, and follow the terms of use (or terms and conditions) and any other documentation relating to a particular Generative AI tool. In cases where the user of a particular Generative AI tool does own the rights in the work, the Company shall be the owner of all works generated by the user.

Users should ensure that they fully understand how the Generative AI uses data inputs before inputting any information or content that is protected by intellectual property rights.

6. Use of generative AI

The Company may use AI for supportive, low‑risk tasks such as:

  • Early idea generation, mood‑board prompts and narrative exploration
  • Rough written drafts, outlines or treatment scaffolds
  • Summaries of non-sensitive content we already understand
  • Light admin support, such as editing text or converting formats
  • Basic organisational tasks (checklists, schedules, draft scripts)
  • Placeholder copy for internal planning that we will fully rewrite

The Company will not use AI for:

  • Final recruitment, selection or HR-related decisions
  • Processing or storing any personal data (names, dates of birth, addresses, unique identifiers)
  • Sensitive or confidential content that could identify contributors, teams or stakeholders
  • Creative direction, strategy, or high‑stakes narrative decisions
  • Legal, financial, compliance‑related or factual conclusions without human verification
  • Final edits, content approvals or deliverables
  • Any work where a client has asked for no AI use

We acknowledge that AI can be wrong, incomplete or misleading. Therefore we always review and fact-check:

  • Names, job titles and organisational details
  • Numbers, timelines, data points and quotes
  • Strategic messaging, tone and sensitive subject matter
  • Anything that could shape public perception, internal comms or reputational risk
  • We remain fully responsible for all creative, editorial and production decisions — and for all work we deliver.

7. Ethical use AI

The Company aims to use AI in ways that align with our purpose‑driven practice and values.

This includes:

  • Choosing tools that respect privacy, fairness and transparency
  • Avoiding technologies that misuse data or reinforce harmful biases
  • Using AI only when it genuinely improves efficiency, creativity or client value—never as a replacement for human judgement, empathy or storytelling
  • Ensuring people-led narratives, contributor dignity and authenticity remain at the heart of our work.

8. Transparency with clients

  • The Company will explain when and how we use AI if it meaningfully affects the process or outputs
  • Clients can request that we avoid AI in their project, and we will respect that
  • We will be clear about which parts of the work were human‑crafted, reviewed and finalised by us.

9. Reporting concerns

Any misuse of Generative AI (suspected or actual; intentional or accidental), other concerns relating to its use, or questions relating to this policy should be referred to one of the directors by emailing hello@digitom.tv, subject: AI Concerns.

10. Review and updates

The Company will review this policy regularly as AI tools evolve, as the business grows, and as industry standards change. Our goal is to continue working ethically, responsibly and in line with our commitment to positive social and environmental impact.

Any changes will be immediately posted here, therefore we recommend that you check this page regularly to keep up-to-date. This AI Usage Policy was last updated on 9th June 2026.