ARTIFICIAL INTELLIGENCE –PRINCIPLES AND USE

I. Principles 

Mintz Group is committed to maintaining the highest ethical and professional standards in its use of Artificial Intelligence (“AI”).  We are confident that AI, when integrated thoughtfully and used responsibly, can enhance our work and provide significant benefits to our clients. Yet, we are also mindful of the risks that certain AI tools carry.  We are constantly evaluating and assessing our use of AI and will strive to address and mitigate risks as we identify them. We set forth below MG’s guiding principles and will amend this document from time to time to reflect our evolving use of AI.

Our focus is on using AI in a responsible way that enhances the quality, accuracy and efficiency of the services we provide to our clients while adhering to our core AI values:  

• Transparency 

• Confidentiality, privacy and security

• Quality and accuracy 

• Integrity

II. AI Used by MG

In the course of processing data to conduct due diligence and other research and analysis on behalf of its clients, MG may use certain AI tools to help ensure that the services are performed efficiently and comprehensively.  In this context, MG’s use of AI includes:

    • In-house proprietary software applications that use Generative GAI to review and prepare preliminary summaries of:

    ◦ publicly accessible press and social media, and other content that has been posted on the Internet or is otherwise available in the public record; and

    ◦ resumes, CVs, bios, or other biographical information provided to MG by MG’s clients or the individual subjects of MG’s background checks and related services;

    • Third-party Internet search engines and proprietary databases that use Generative AI to conduct searches of publicly accessible press, social media and other content that has been posted on the Internet or is otherwise available in the public record;

    • Third-party proprietary Identity Verification software¹ that may be used to help facilitate identity checks on individuals through the processing of biometric data and the use of facial recognition technology; and Third-party proprietary databases that use Generative AI to review the terms of MG’s contracts with MG’s clients.

    To the extent that MG may use publicly available AI software applications, MG will ensure that the providers (“Providers”) of those applications observe data confidentiality, security, and other compliance standards that are at least equivalent to those observed by MG.  To the extent data pertaining to MG’s clients or the subjects of MG’s background checks is entered into these publicly available applications, any output data would only be accessible to MG for the purposes of conducting the relevant work and will not be used for AI model training or shared with any unauthorized parties.  The data may be accessible to Providers to the extent necessary to run the application and comply with applicable laws.

    All information and outputs generated by the above-listed AI tools are subject to a human review for accuracy and quality prior to being shared with MG’s clients, unless otherwise stated in a specific MG product offering, engagement letter or other correspondence with MG’s clients.

    III. AI Not Used by MG

      • MG does not use AI that involves automatic decisionmaking

      • MG does not use AI that provides automatic scoring

      • MG does not use AI that evaluates resumes for purposes of making hiring decisions

      • MG does not use AI that processes biometric data apart from the Identity Verification tool described above

      • MG does not use AI for the purpose of selecting, evaluating, surveilling, or making decisions about a person in an employment-related context such as hiring, promotion or performance

      • MG does not use AI for the purpose of making decisions about a person’s access to products and services

      • MG does not use AI that collects facial images for facial recognition databases

      • Data pertaining to MG’s clients or the subjects of MG’s background checks, is not used to train AI without first being anonymized 

      • MG does not use any of the following data as input into any AI tool unless specifically requested by its client:

      ◦ Intellectual property of any third party

      ◦ Protected health information

      ◦ System access credentials, such as passwords

      IV. Disclosures and Opt-Outs

      MG remains available to address any questions that its clients may have about MG’s use of AI.  

      ¹ The use of this software is contingent on the individual logging into an MG portal and providing informed consent before the Identity Verification check is conducted.

      Any individual seeking to opt out of MG’s use of any of the above-described AI, should contact MG at dataprotectionteam@mintzgroup.com. MG reserves the right to refer  individual inquiries to the client on whose behalf MG is processing the individual’s data.  Additional information about MG’s procedure for responding to individual requests can be found at https://mintzgroup.com/gdpr/. 

      MG’s use of AI as described in this statement shall be subject to the approval and instructions of MG’s clients on whose behalf MG processes personal data, subject to MG’s privacy policies at https://mintzgroup.com/gdpr/ and https://mintzgroup.com/privacy-policy/.