Artificial Intelligence (AI) Usage Policy


1. Purpose and scope


This policy has been drafted to support Orange PR & Marketing Ltd in using AI tools ethically, legally, and effectively so that we protect our clients and demonstrate best practice at all times. AI is a rapidly advancing technology and we will update this policy at regular intervals.


This policy applies to all directors, employees, contractors, freelancers and associates of Orange PR & Marketing Ltd ("Orange", "we", "us") who use AI tools in the course of work carried out for the company or its clients. It sits alongside our Privacy Policy, Data Protection Policy and client contracts. Where a client agreement sets stricter requirements than this policy, the client agreement takes precedence.


At Orange PR & Marketing Ltd we are committed to identifying and capturing opportunities arising from emerging technologies. We are encouraged to be curious about new technology, expand our understanding of how they can be used and how they work, and use them within the parameters set out in this policy.


While we are aware of the potential offered by AI tools, we also acknowledge the limitations and pitfalls, and continually seek to uphold factual accuracy, observe ethical usage, and continually refine our approach to using them.


Our core principles


Our use of AI tools will support three core principles:


  • Quality: We are cautious and circumspect in our approach to working with generative AI tools, using them for research and ideation. We will check and cite with care, to avoid being susceptible to bias and misinformation.
  • Protection: We will follow developments in legal regulation closely to ensure we are protecting our content and our clients from issues relating to copyright and fair use of data.
  • Privacy: We will adhere to the principles of UK GDPR, being transparent in our use of generative AI and how we collect and store data.


Underpinning all three: human accountability. AI can speed up our work, but it does not replace professional judgement. A named member of the Orange team owns and is accountable for every output that reaches a client or the public. Responsibility for the accuracy and quality of that work always rests with the person who signed it off, never with the tool.


2. Legal and regulatory compliance


The UK does not currently have a single, dedicated AI law. Instead, our use of AI is governed by a range of existing laws and regulators, all of which we comply with. These include, but are not limited to:


  • Data protection law — the UK GDPR and the Data Protection Act 2018 (as amended by the Data (Use and Access) Act 2025), regulated by the Information Commissioner’s Office (ICO). We apply the ICO’s guidance on AI and data protection.
  • The Equality Act 2010 — we take steps to prevent AI outputs that discriminate against or misrepresent people on the basis of protected characteristics.
  • Copyright and intellectual property law — principally the Copyright, Designs and Patents Act 1988 (see section 8).
  • Advertising and consumer protection law — including the UK Advertising Codes (CAP/BCAP) enforced by the ASA, and consumer protection legislation. AI-assisted marketing and PR content we produce must remain accurate, non-misleading and clearly identifiable as advertising where required.
  • Confidentiality obligations owed to our clients under contract and at common law.


We monitor developments in UK AI regulation, ICO codes of practice and guidance, and will update this policy as the legal landscape evolves.


3. Essential terms


Orange PR & Marketing Ltd is incorporated and registered in England with company number 15408810, whose registered office is The Nursery, Layer Marney Tower, Roundbush Road, Layer Marney, Colchester, England, CO5 9US.


Artificial intelligence, or AI, refers to the simulation of human intelligence in machines that are programmed to think and act like humans.


Generative AI is a broad label for any type of AI that can be used to create new text, images, video, audio, or code.


Large Language Models (LLMs) are part of this category of AI. They are trained on vast amounts of existing data and generate human-like text.


ChatGPT, Canva AI, Google Gemini, Microsoft Copilot, Claude by Anthropic, and Perplexity AI are publicly available web-based versions of generative AI that allow users to enter text prompts and either seek a view from the system or ask the system to create output based on a given subject.


Public (or "open") AI tools: tools where data you enter may be stored, reused, or used to train the provider’s models or improve its services. There is a risk that sensitive or confidential information could be retained, repurposed, or accessed by others. We treat anything entered into these tools as though it could become public.


Private (or "enterprise") AI tools: tools configured under a business agreement so that inputs are not used to train public models or shared with others, keeping information private to Orange and our clients.


4. How we use AI at Orange PR & Marketing Ltd


Evaluating and experimenting with new tools has always been part of our way of working at Orange PR & Marketing Ltd, and with AI we tread a cautious balance between making the most of the opportunities for efficiency these new tools give us and staying true to our core principles of best practice in communications.


We maintain an internal list of AI tools that have been approved for use at Orange. New tools are assessed against this policy, including their data-handling and training terms, before they are used on client work. We review this list regularly and invest in training so the team uses AI well and safely.


We are currently using:


ChatGPT and Claude on paid Pro/Team plans, in which prompts and uploaded files are processed to generate and refine content. This data is used only to provide responses to us and not shared for other purposes. We have opted out of having our data used to train the providers’ models.


Fathom and Otter to transcribe and record conversations in Google Meet, Zoom and Teams meetings, as well as in-person meetings. We seek and record permission in advance of all recordings (see section 12).


We support sustainable practices in digital activity


Training AI tools on large data sets, using them to process information, and storing this data has a significant carbon footprint.


We will carefully consider our usage so we strike a balance between realising the potential of AI tools and lessening the environmental impact where possible.


5. Content creation


Using AI text generators


Orange PR & Marketing Ltd may use text generators for topic research.


Generative AI tools like ChatGPT and Claude are capable of processing large quantities of information to quickly summarise complex topics.


When using text generators to research a topic, we will always fact-check and cross-check the resulting material to ensure false information is not mistaken as fact. We will never put sensitive or private client data into a text generator where the information could be shared publicly.


We may use text generators to spark ideas and inspiration.


AI tools can support us in project research and idea generation, similar to how we might ask a colleague for an idea on how to approach a creative task. We use them for audience and competitor research, for example in a strategy or copywriting project, to bring in different perspectives and complement the insights from the client themselves.


We may use AI to organise information, including:


  • Cross-referencing content across multiple documents
  • Organising content, for example into tables and glossaries
  • Formatting content, for example changing the layout or removing time codes from transcriptions


We will always prioritise quality and authenticity in the content we produce.


We will be critical and responsible users of generative AI tools. That means not publishing anything written entirely by them. Material gathered from a text generator will not be copied and pasted into internal or public-facing material without human editorial processing.


Through human editorial processing, Orange PR & Marketing Ltd will always:


  • Ensure all content is factually correct and ethically sound
  • Edit wording to the appropriate tone of voice and brand guidelines
  • Check for biases and stereotypes
  • Avoid plagiarism and check for potential copyright infringement


With this in mind, we will not publish any written content that is 100% produced by generative AI. We will always apply brand guidelines, fact-check responses, and re-write in our own words.


Using AI audiovisual tools


Orange PR & Marketing Ltd may use image tools to correct and make minor edits.


Image editing with AI tools can speed up our work. We may use these tools to make minor changes to a photo, to make it more usable without changing the subject matter or original essence. For example, if we require a photo in landscape ratio but only have one in portrait, we might use Canva’s inbuilt AI tools to extend the background to create an image with the correct dimensions for a website.


We will use image editing tools ethically.


We do not use any image or video editing tools to change the essence of any original visual content, on our website, social media, or anywhere else. For example, we do not change the expressions, appearance, ethnicity, or any other core features of those captured in photography, video and images.


We may use audio and video tools to remove distractions for audiences.


AI audio and video tools can help us save time on creative projects. For example, our team can save hours of editing time by using audio clean-up tools to remove unwanted background noise, or video tools to remove distractions in shots.


AI tools may be used for creating subtitles in video editing programs.


This saves us time, enabling us to pass the cost saving on to our clients. Some social media platforms will use AI to create voiceovers to go with subtitles too. We will always proofread the final content that goes out to ensure accuracy.


Orange PR & Marketing Ltd does not use voice clone generators or create deepfake videos.


We do not use AI tools to recreate the voice or appearance of any real person without their explicit, documented consent, given the significant ethical and legal risks. Where we use AI-generated or AI-manipulated imagery, audio or video in published material and there is any risk of an audience mistaking it for real, we will label it clearly as AI-generated.


6. Data protection, confidentiality and information security


Orange PR & Marketing Ltd does not input any sensitive, private, personal, confidential or embargoed information into public/open AI platforms.


Text generators allow users to paste in articles or data and build a prompt around them, such as “write a social media post about this article” or “analyse this data and tell me about the trends”. The terms of use of many AI tools are not clear on how inputs are stored or may be accessed in future. We will not input any confidential or restricted data into public AI tools, in the same way that we would not share it on social media, in an external email, or discuss it in public.


In addition, to comply with UK data protection law:


We will not enter personal data (information that identifies a living individual) into any AI tool unless we have a lawful basis to do so and the tool is approved and appropriately contracted for that purpose.


Where an AI tool provider processes personal data on our behalf, we will ensure an appropriate data processing agreement is in place and that the provider offers adequate security and, where relevant, appropriate safeguards for any transfer of data outside the UK.


We carry out a Data Protection Impact Assessment (DPIA) before using AI in any way that is likely to result in a high risk to individuals’ rights, in line with ICO guidance.


We apply the UK GDPR principles of lawfulness, fairness and transparency, purpose limitation, data minimisation, accuracy, storage limitation, and security to all AI-assisted processing.


We do not use AI to make solely automated decisions that produce legal or similarly significant effects on individuals without appropriate safeguards and human review.


If you believe personal or confidential data may have been entered into an AI tool in error, you must report it immediately so we can assess whether it is a data breach requiring action (see section 11).


7. Transparency with our clients


We are open with clients about how AI features in our work. If a client asks, we will tell them which tools were used and what we changed. Where a client asks us not to use AI on their account, or to use it only in defined ways, we will follow that instruction and record it.


8. Intellectual property and ownership of AI outputs


Ownership and copyright in AI-generated content is a developing and uncertain area of UK law. Content produced wholly or partly by generative AI may not attract copyright protection in the same way as work created by a person, and there is a risk that AI outputs could unintentionally reproduce third-party material. Because of this:


We respect intellectual property and copyright. We check AI-assisted material for potential infringement before it is used or published.


We cannot and do not guarantee that copyright or other intellectual property rights will subsist in, or be enforceable over, content that is generated by AI. Where ownership of deliverables matters to a client, we will agree the position in writing in advance.


Our own training materials, frameworks, templates and methodologies remain the intellectual property of Orange PR & Marketing Ltd (see section 12).


9. Accuracy, bias and human oversight


AI tools can produce inaccurate, outdated, biased or fabricated information ("hallucinations"). Every AI-assisted output passes through a human checkpoint before it reaches a client or the public. A named member of the team owns the accuracy, quality, tone and fairness of that output. We train our team to recognise and prevent output that is biased, harmful, discriminatory, misleading or offensive, and to check for stereotyping and misrepresentation of people and communities.


10. Governance, training and reporting concerns


This policy is owned by Orange PR & Marketing Ltd. The responsible contact for the policy is Megan Dorian. Any questions about whether a particular use of AI is permitted should be raised with them before proceeding. If you become aware of a breach of this policy, a suspected data breach, a copyright concern, or an AI output that has caused or could cause harm to a client or third party, report it to the responsible contact without delay. We keep the team’s AI training and this policy under regular review.


11. Meetings, training and webinars


We will not record or store content without consent


AI transcription tools such as Otter, Fathom and features built into Zoom and other video communication platforms enable meetings to be transcribed and the audio recorded and stored. These tools are becoming widely used, but not everyone understands how they work or what it means when they agree to being recorded.


We may request consent to record an online meeting using these tools when we need to gather information for content creation, for example an interview to help us write a blog post. We will give advance notice.


We will use AI notetaker tools to transcribe sales meetings or other business discussions, but only following consent or a request to do so from the other party; it will not be a matter of routine.


We request that our training sessions and webinars are not recorded


Our training has been built and refined over many years and we own the intellectual property in this content. We ask that attendees do not use transcription tools to record, store or share it. We are also mindful that not everyone on the call will have given consent for their input to be recorded.


We reserve the right to end the session or remove people from the call if they do not abide by this policy.


12. Review and version control



This policy will be reviewed and updated on a regular basis. It was last updated on 29 July 2026 and is scheduled for review by January 2027, or sooner if the law or our practices change materially.