1. Purpose
This policy sets out how [Organisation] considers requests to use AI-assisted tools (writing assistants, transcription, summarisation, task-planning, or similar) as a reasonable adjustment under the Equality Act 2010, and the data governance checks that apply before any such tool is approved for use.
2. Scope
Applies to any employee, worker, or contractor requesting to use an AI tool - whether provided by the organisation or brought by the individual (a "bring your own AI" request) - to support a disability, long-term condition, or neurodivergent processing difference in carrying out their role.
3. Principle
A request to use an AI tool as an adjustment is treated the same as any other adjustment request: assessed on the individual’s needs, not on assumptions about their diagnosis or job role, and not refused solely because the tool is unfamiliar to the line manager.
4. The approval route
No AI tool - organisation-provided or personal - processes work data until it has been through the Approved AI Tool Matrix (Section 3 of this pack) and, where personal or special category data is involved, a completed DPIA (Section 2). This applies even where the individual already uses the tool personally outside work.
5. Data minimisation
Where an AI tool is approved, its use is scoped to the minimum data necessary for the adjustment to work - for example a transcription tool need only process the individual’s own meeting audio, not an entire shared drive.
6. Line manager responsibility
Line managers do not approve AI tools themselves. Their role is to receive the request promptly, avoid informal refusal ("we don’t really do that here"), and route it to the named approver (Section 4, the manager guide) within 5 working days.
7. Review
Approved tools are reviewed annually, or sooner if the vendor changes its data processing terms, a data breach affecting the tool is reported, or the individual’s needs change. A tool can be withdrawn from the approved list without withdrawing the underlying adjustment - an alternative is offered first.
8. Related policies
This policy sits alongside, and does not replace, the organisation’s existing Reasonable Adjustments Policy, Data Protection Policy, and Acceptable Use Policy. Where they conflict, the Data Protection Policy’s requirements take precedence.
Replace [Organisation] throughout with your organisation’s name, and route Section 4 to whoever actually holds information-governance sign-off in your structure - a DPO, an information governance lead, or (in smaller organisations) a named senior manager working from the DPIA template in Section 2.
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