Privacy and data protection

AI Acceptable Use Policy


Last updated: 28 September 2025

Introduction

The vision for the integration of generative artificial intelligence (“GenAI”) into our services is as follows:

  1. To commit to advancing education by integrating transformative technologies throughout our platforms in a consistent way
  2. To promote the ethical use of GenAI through designs that maximise AI's utility while also ensuring responsible use
  3. To offer GenAI services with better transparency, intentionality, and personalisation than our competition
  4. To establish trust by utilising focus groups and feedback sessions to inform product development and prioritisation
  5. To supercharge customer support by enabling more productive agent problem-solving with GenAI technologies.

Pamoja Education Ltd (“Pamoja” or “PMJ” or “we”) is therefore committed to providing a safe and secure environment for all its employees, contractors, partners and customers, including our responsible use of generative AI tooling. This Acceptable Usage Policy (“AUP”) outlines the guidelines and principles that employees and the organisation need to follow when using generative AI capabilities. The purpose of this policy is to ensure that our employees use generative AI systems in a manner that is consistent with our Founding Principles. This policy applies to all PMJ employees who use GenAI systems for their roles and responsibilities. By following this policy, we will aim to ensure that generative AI tooling remains a valuable capability for designing, developing and building solutions for our employees, contractors, partners and customers, whilst ensuring the ways in which we service our customers with generative AI are secure and in-line with our Information Security Policy.

Acceptable terms of use at Pamoja

  • The use of generative AI tooling should be limited to business-related purposes and in line with the values of the organisation.
  • All assets created through the use of generative AI systems must be professional and respectful. Employees should avoid using offensive or abusive language and should refrain from engaging in any behaviour that could be considered discriminatory, harassing, or biased when applying generative techniques. However, exceptions may apply to planned and deliberate actions taken by authorised employees and contractors for the purpose of sufficiently testing and/or improving a GenAI system.
  • Employees must not share any confidential or sensitive information with GenAI tooling, including but not limited to sensitive information, passwords, certificates, personally identifiable information (“PII”), asset names, secrets and tokens unless rationale of such sharing has first been considered and approved by the AI Ethics Team.
  • Employees must protect their login credentials and ensure that their generative tooling accounts are not accessible to unauthorised individuals.
  • Generative AI systems must be used in compliance with all applicable laws and regulations, including data protection, privacy laws, geographical restrictions and our Information Security Policy.
  • An AI Ethics Team has been created to review and address any questions and issues raised by employees, contractors, partners or customers in regards to generative AI usage.

Employee responsibility for AI

  • Employees are responsible for ensuring that they, and their contractors, partners and customers, use GenAI in compliance with this AUP and any other relevant policies or procedures.
  • Employees are responsible for ensuring that there is always human involvement when setting up using GenAI tooling, and for the receipt and analysis of data and outputs generated by the AI tooling.
  • All employees must be aware of their responsibilities for protecting confidential and sensitive information and must take all necessary steps to safeguard the privacy and security of this information when using GenAI tooling.
  • Managers and supervisors are responsible for ensuring that their teams are aware of and comply with this policy. They must report any violations of this policy, for example those relating to partners and customers, to the Senior Leadership Team.
  • Pamoja’s Senior Leadership Team is responsible for agreeing and documenting an approved list of GenAI systems to ensure that only authorised applications of these technology capabilities are applied by the business.
  • Our parent company’s Legal & Compliance Officer is responsible for ensuring that GenAI tooling is being used in compliance with all applicable laws and regulations, including data protection, privacy laws and geographical restrictions.
  • Employees may use GenAI tools to assist in creating public-facing content, as long as guidelines are followed. Any GenAI incorporated in PMJ products must always be verified by a human.
  • Employees will identify GenAI when it has been used for public communications and custom-facing content.

Pamoja responsibility to customers

  • Any generative AI incorporated in our products will be vetted against discriminatory, biased, or harassing behaviour.
  • Any generative AI incorporated in our products is to benefit and support our customer’s work in education, it is not to replace anyone or anything.
  • We are not responsible for the output of the GenAI, but will do our best to limit the output to educational needs.
  • We will provide visibility to our customers of any AI created content.
  • We will allow customers to opt in to GenAI; customers will not be forced to use or adopt GenAI in any of our platforms.
  • We will state when AI has been used in our content creation.

How AI will not be used at Pamoja

  • We will not reenact someone by using GenAI, without their explicit consent.
  • We will not use GenAI to create any content that is illegal, discriminatory, defamatory, or otherwise offensive or inappropriate to our employees, contractors, partners and customers.
  • We will not use GenAI to harass, bully, intimidate, or discriminate against other employees or external parties.
  • We will not use AI:
    • To share confidential or sensitive information with unauthorised individuals, including external parties that provide GenAI services.
    • To engage in any activity that could compromise the security or integrity of the business using generative AI systems, including attempting to open up access to unauthorised data sets and systems.
    • To violate any applicable laws or regulations, including data protection, intellectual property, privacy laws or geographical restrictions.
  • PMJ will not develop, train, or improve generalised AI and/or machine learning models.