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FREMAP recognizes the relevance of the use of Artificial Intelligence (AI) to fulfill its objectives as a collaborating entity with Social Security, in accordance with the provisions of Article 80 et seq. of the Consolidated Text of the General Social Security Law, highlighting the benefits it can provide, especially in relation to the efficiency and automation of processes. AI is to be used responsibly and ethically, thus minimising any risks which may result from its application. Furthermore, the use of AI will be carried out following the principles of service, respect, equality, transparency and social responsibility, as set out in FREMAP's Code of Conduct. AI may never be used in FREMAP for the commission of a criminal offence, whether directly or indirectly.
FREMAP's Artificial Intelligence (AI) Use Policy has been established in accordance with European regulations and, in particular, with Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024 laying down harmonised rules in the field of artificial intelligence and amending Regulations (EC) No 300/2008, (EU) No 167/2013, (EU) No 168/2013, (EU) 2018/858, (EU) 2018/1139 and (EU) 2019/2144 and Directives 2014/90/EU, (EU) 2016/797 and (EU) 2020/1828 (Artificial Intelligence Regulation).
The commitments and guidelines established in this policy must be considered in all use, deployment, modification and development of artificial intelligence initiatives and systems carried out by employees and members of the governing and participatory bodies of FREMAP.
It will also apply to external professionals or suppliers associated with FREMAP by means of a works or services agreement under the clauses included in their agreements.
This document will come into effect the day after its approval by the Managing Director of the entity, and will be communicated to all employees through the corresponding Circular, which will be published on the entity's website. It will also be reported to the members of the entity's participation bodies.
FREMAP will ensure that all employees and members of the governing and participatory bodies have the necessary training to make responsible use of AI, respecting current legislation, FREMAP's internal regulatory framework and this policy.
The following principles will govern the use of AI in the entity:
- Respect for fundamental rights and human oversight. In the use, deployment and development of AI, the person will always be taken into account, respecting fundamental rights and human dignity, adopting at all times mechanisms of human supervision that allow to guarantee it. Special attention should be paid to diversity, non-discrimination and equity in the monitoring and mitigation of discriminatory biases.
- Regulatory and usage compliance. The use of AI will be carried out in compliance with current legislation on AI, as well as strictly as established in this policy document and the entity's internal rules. Practices specified in current regulations are prohibited, as well as those that do not comply with the provisions of this policy. Likewise, privacy management and the processing of personal data must be adopted in accordance with the applicable regulations. In general, the use of any AI system that has not been expressly authorised by the entity following a risk analysis is banned.
- Technical security. FREMAP will ensure that its systems are secure, reliable, robust and resistant to cyberattacks, thereby enhancing their overall security.
- Transparency. This policy guarantees transparency in the information used and ensures that the use of AI optimizes our operations in all areas, all for the sake of efficient service. The highest levels of transparency and explainability must be adopted towards the people involved in the deployment of AI systems, reporting on the interaction with said systems, documenting the decisions taken, and any other circumstances. This will prevent any instances of opacity in processes that could lead to criminal and administrative liability.
- Systems audit. Our systems are audited periodically and have the necessary mechanisms to minimize any problems they might encounter. Specific audits of AI systems will ensure their responsible and diligent use. Periodic reviews and monitoring of the results generated will also be carried out in order to identify possible failures or malfunctions that could pose a compliance risk for FREMAP.
- Third-party rights. FREMAP guarantees respect for the rights of third parties (Intellectual and Industrial Property), in cases of use of generative AI.
- Staff training and awareness-raising. FREMAP will ensure the diligent and responsible use of AI, as well as the application of good practices in its use, ensuring that all staff understand the implications, risks and benefits of AI.