LES DAMES D’ESCOFFIER
LONDON CHAPTER
— Policies and Governance —
ARTIFICIAL INTELLIGENCE (AI) USE POLICY
Version 1.0 | February 2026
Registered Charity, England & Wales
An affiliate chapter of Les Dames d’Escoffier International (LDEI), USA
ARTIFICIAL INTELLIGENCE (AI) USE POLICY
Policy Overview
Organisation: Les Dames d’Escoffier, London Chapter
Type: Registered Charity — Women in Food, Beverage & Hospitality
Policy: Artificial Intelligence (AI) Use Policy
Version: 1.0
Effective Date: February 2026
Review Date: February 2027
Approved by: Board of Trustees
1. Purpose and Scope
Les Dames d’Escoffier, London (hereafter “the Chapter”) is a women-led membership organisation and registered charity dedicated to supporting and championing women leaders in the food, beverage, and hospitality industries. This Policy sets out how the Chapter will use Artificial Intelligence (AI) tools responsibly, ethically, and in compliance with United Kingdom law, including guidance from the Information Commissioner’s Office (ICO).
This Policy applies to:
All trustees, board members, and officers of the London Chapter
Volunteers, contractors, and consultants acting on behalf of the Chapter
All use of AI tools in connection with the Chapter’s activities, including communications, events, grant-making, scholarships, and mentorship programmes
Any processing of data shared with or received from Les Dames d’Escoffier International (LDEI), USA
2. Definitions
For the purposes of this Policy, the following definitions apply:
Term
Definition
AI Tool
Any software, application, or system that uses machine learning, natural language processing, generative AI, or other algorithmic processes to assist with tasks. Examples include ChatGPT, Microsoft Copilot, Google Gemini, Claude, Grammarly, and similar tools.
Generative AI
AI systems capable of producing text, images, audio, or other content in response to user prompts.
Personal Data
Any information relating to an identified or identifiable living individual, as defined under the UK GDPR and the Data Protection Act 2018.
Special Category Data
Personal data that warrants higher protection under UK GDPR Article 9, including data relating to health, racial or ethnic origin, religious beliefs, or sexual orientation.
LDEI
Les Dames d’Escoffier International, the USA-based international organisation with which member data may be shared.
IDTA
UK International Data Transfer Agreement — the mechanism used to lawfully transfer personal data from the UK to countries without UK adequacy status.
Data Bridge
The UK–US Data Bridge (in force October 2023), a framework under which certified US organisations can lawfully receive personal data from the UK without additional transfer safeguards.
3. Guiding Principles
The Chapter’s use of AI is guided by the following principles, which reflect our values as a women-led charity in the food and hospitality sector and align with the ICO’s framework for responsible AI use:
3.1 Responsible and Ethical Use
We will use AI in a manner consistent with our charitable objectives and our commitment to our members, volunteers, and the communities we serve. AI must not be used in ways that are discriminatory, misleading, harmful, or contrary to the Chapter’s values.
3.2 Human Oversight
AI tools are assistants, not decision-makers. All material decisions — including grant and scholarship awards, membership applications, communications with beneficiaries, and financial matters — must be reviewed and approved by a person with appropriate authority. AI-generated content must always be critically reviewed before use or publication.
3.3 Data Protection and Privacy
The Chapter is committed to full compliance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and all applicable guidance from the ICO, including the ICO’s guidance on AI and data protection. Personal data must never be entered into third-party AI tools unless a lawful basis exists and appropriate data processing agreements are in place.
3.4 Transparency and Honesty
Where AI has played a material role in creating content published or communicated by the Chapter, this should be acknowledged. We will not misrepresent AI-generated content as entirely human-authored where that distinction is material to the audience.
3.5 Fairness and Non-Discrimination
We recognise that AI systems can embed and amplify biases, including gender bias, racial bias, and cultural bias. We will monitor AI outputs for discriminatory content and will not use AI in any way that disadvantages a person on the basis of a protected characteristic under the Equality Act 2010.
4. Permitted Uses of AI
The following uses of AI are permitted, subject to compliance with this Policy:
Drafting, editing, and proofreading correspondence, newsletters, and promotional materials
Creating first drafts of grant communications, press releases, event descriptions, and social media posts — subject to human review and approval before publication
Research and information gathering to inform programme development or industry trends, where outputs are independently verified
Summarising publicly available information or internal meeting notes that contain no personal data
Generating images or visual assets for events and publications — subject to intellectual property review before use
Translation assistance for multilingual communications
Accessibility improvements, such as generating image alt-text
Administrative drafting tasks such as template responses or scheduling text, where no personal data is processed
5. Prohibited Uses of AI
The following uses of AI are strictly prohibited:
Entering personal data, membership details, financial information, or special category data into publicly accessible or free-tier AI tools (such as the free versions of ChatGPT, Google Gemini, or similar services)
Using AI to make, or to automate without human oversight, decisions about membership, grants, scholarships, or the exclusion of any individual
Creating deepfakes, synthetic media depicting real individuals, or any misleading or fabricated content
Producing content that is discriminatory, offensive, or in breach of the Chapter’s values or the Equality Act 2010
Using AI to impersonate trustees, officers, members, or external stakeholders
Submitting AI-generated content to funding bodies or grant applications without disclosure, where the funder’s terms require it
Using any AI tool that has not been assessed under this Policy where personal data may be processed
6. Data Protection and the ICO
6.1 ICO Registration
Any organisation that processes personal data is required to register with the ICO and pay the applicable data protection fee, unless exempt. The Chapter’s Data Protection Lead is responsible for ensuring that the Chapter’s ICO registration is current, accurately reflects its processing activities, and is renewed annually. ICO registration can be verified and renewed at ico.org.uk.
6.2 UK GDPR Compliance
Any use of AI that involves or could involve personal data must comply with the UK GDPR and the Data Protection Act 2018. Before using an AI tool to process personal data, the responsible person must:
Confirm a lawful basis for processing under UK GDPR Article 6 (and Article 9 for special category data)
Review the AI provider’s privacy policy and data processing terms to understand how data is handled
Ensure a Data Processing Agreement (DPA) is in place where the AI provider acts as a data processor on the Chapter’s behalf
Conduct a Data Protection Impact Assessment (DPIA) where the processing is likely to result in a high risk to individuals, in line with ICO guidance
The ICO has published specific guidance on AI and data protection, including on the use of generative AI tools. The Data Protection Lead should consult this guidance — available at ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/artificial-intelligence — before approving the use of any new AI tool.
6.3 International Data Transfers to LDEI (USA)
The Chapter may share member data and programme information with Les Dames d’Escoffier International (LDEI) in the United States as part of its affiliate obligations. Any such transfer of personal data must be carried out lawfully. The appropriate mechanism will depend on whether LDEI is certified under the UK–US Data Bridge:
If LDEI is certified under the UK Extension to the EU–US Data Privacy Framework (the “UK–US Data Bridge”, in force from 17 October 2023), personal data may be transferred to LDEI without additional safeguards under that certification.
If LDEI is not certified under the Data Bridge, transfers must be governed by a UK International Data Transfer Agreement (IDTA) or equivalent approved safeguard, accompanied by a Transfer Risk Assessment (TRA).
The Data Protection Lead is responsible for confirming LDEI’s certification status before any transfer takes place, and for ensuring that appropriate documentation is in place and kept up to date.
6.4 AI Tools and Third-Party Data Sharing
Many consumer-facing AI tools may use inputted data to train their models or share data with third parties. To manage this risk:
Only enterprise or business-grade versions of AI tools — which offer data isolation and contractually commit not to use inputs for model training — may be used where member, applicant, or stakeholder data is involved
Free-tier AI tools may only be used for entirely non-personal, anonymised, or publicly available content
7. Intellectual Property
The copyright position on AI-generated content is not fully settled under current UK law. Until further clarity emerges, the Chapter will:
Not assert copyright ownership over content known to be entirely AI-generated without first seeking legal advice
Ensure that AI tools used for content creation do not reproduce third-party copyrighted material
Maintain a record of significant AI-generated content and the tools used to produce it
Review AI-generated text and images for potential copyright issues before publication or external use
8. Approved AI Tools
The following categories of tools may be used by the Chapter, subject to Board approval and compliance with this Policy. A register of approved tools shall be maintained by the Data Protection Lead:
Tool Category
Conditions for Use
Enterprise / Business Generative AI (e.g. Microsoft 365 Copilot, Google Workspace AI, Claude for Teams, ChatGPT Team / Enterprise)
Permitted for drafting, summarisation, and administrative tasks. Personal data may only be processed where a DPA is in place and, where required, a DPIA has been completed.
Spelling and Grammar Tools (e.g. Grammarly Business)
Permitted. Avoid inputting sensitive or personal data. Confirm the business version’s data terms before use.
Free-tier Generative AI (e.g. ChatGPT Free, Google Gemini Free)
Permitted for non-personal, anonymised, or publicly available content drafting only. Must never be used with member, applicant, or stakeholder data.
AI Image Generators (e.g. Adobe Firefly, Microsoft Designer)
Permitted for event and marketing assets. Intellectual property review required before publication.
AI Translation Tools
Permitted for non-personal content. A DPIA is required if personal data is involved.
Any tool not listed above must be reviewed and approved by the Board before use.
9. Roles and Responsibilities
Role
Responsibility
Board of Trustees
Approve this Policy and any material revisions. Ensure adequate resources are available for compliance. Receive an annual report on AI use and data protection matters.
Chair / President
Champion responsible AI use across the Chapter. Act as the escalation point for concerns that cannot be resolved by the Data Protection Lead.
Data Protection Lead
Maintain the register of approved AI tools. Confirm ICO registration is current. Oversee DPIAs, DPAs, and LDEI data transfer arrangements. Act as the primary point of contact with the ICO.
All Officers & Volunteers
Follow this Policy at all times. Seek approval before using any new AI tool. Report concerns or potential breaches promptly to the Data Protection Lead.
10. Training and Awareness
The Chapter will ensure that all trustees, officers, and active volunteers who use AI tools in connection with the Chapter’s activities receive appropriate guidance on this Policy. This will be delivered through:
Induction materials provided to all new trustees and officers
Annual briefings or written updates, particularly where the Policy or ICO guidance has changed
Signposting to ICO guidance on AI and data protection, available at ico.org.uk
11. Monitoring and Review
This Policy will be reviewed annually by the Board, or sooner in the event of:
Significant changes to UK law, the UK GDPR, or ICO guidance on AI and data protection
Material changes to the AI tools used by the Chapter or to the tools available on the market
A data breach, ICO investigation, or incident involving AI
Changes to the Chapter’s relationship with LDEI or to the status of LDEI’s UK–US Data Bridge certification
The next scheduled review date is February 2027. The Board will record its review in the minutes of the relevant meeting.
12. Concerns and Complaints
Any member, volunteer, or stakeholder who has a concern about the Chapter’s use of AI, or who suspects a breach of this Policy or of data protection law, should raise it with the Data Protection Lead or the Chair in the first instance. Complaints will be handled in accordance with the Chapter’s general complaints procedure.
Where a concern relates to a potential breach of the UK GDPR or the Data Protection Act 2018, individuals also have the right to raise a complaint directly with the Information Commissioner’s Office (ICO) at ico.org.uk or by calling 0303 123 1113.
Approved by the Board of Trustees, Les Dames d’Escoffier, London Chapter
February 2026