AI (Artificial Intelligence) Review Board: FAQ
This article features answers to Frequently Asked Questions about the AI Review Board and related processes.
*NOTE: RED text within asterisks below comes directly from VCSU AI policy V1203.03.*
A. What is the AI Review Board?
The AI Review Board is mandated by VCSU V1203.03 Artificial Intelligence Policy to *oversee the development and deployment of AI Projects and Systems at VCSU. Furthermore, the AI Review Board reviews associated complaints or grievances. The AI Review Board consists of the Chief Information Officer, one Technology Services staff member appointed by the Chief Information Officer, the Chair of the IRB (Institutional Review Board), the Chair of the CSSE (Computer Systems and Software Engineering) department or their designee, and one faculty member selected by the Faculty Association and serving a two-year term.*
B. When is AI Review Board Approval Required?
It depends on what you are trying to do with AI. Please determine the activity category (1, 2, or 3) below to begin - reference the definitions at the end, if needed:
1. Query AI to obtain information, also known as an AI Prompt
Approval is required if you answer YES to a, b, OR c below.
If Yes, Approval is required – complete the One Stop AI Request form. There is one exception: *NOTE: AI Review Board permission is not required to use AI capabilities integrated within approved NDUS CTS (Core Technology Services) or VCSU Enterprise Systems that may contain private, restricted, or confidential data provided all other provisions of this policy are met.* As of September 26, 2024, approved systems qualifying for this exception include the following:
- Anthology Blackboard and Microsoft Copilot within the Microsoft 365 environment which is a subscription service with a monthly fee.
- Additionally, the free enterprise version of Microsoft Copilot within Bing or Chrome may be used to enter student assignments (private data per FERPA) PROVIDED the enterprise version is used. The enterprise version typically requires the user to enter their NDUS credentials. The attachments, prompts and Copilot replies are not shared with other users or used to train the AI model. There is a non-enterprise version that does not require a user to enter their NDUS credential and entry of private, restricted or confidential data is prohibited when using this version. To ensure you are using the enterprise version of Copilot two things must be present: 1. Your picture, name or initials will appear in the upper right corner of the main window banner that begins with the Microsoft logo on the far left, and 2) a shield symbol that states, "Enterprise data protection..." when hovered over or read by a screen reader will be present immediately below the main banner. If a user is not absolutely certain they are using the enterprise version of Copilot, private data shall NOT be entered.
NOTE: Student assignments (private data per FERPA) that are de-identified may be entered into other AI systems, such as ChatGPT. This comes with a significant caution because there must be nothing in the associated prompts, the body of the document(s), or any other part of the document(s) that could be used to identify the student creator.
b. Will you *attempt to query AI systems to produce information classified as private, restricted, or confidential by policy or law without a VCSU official business need to know?*
If Yes, Approval is required – complete the One Stop AI Request form.
*NOTE: AI Review Board permission is not required to use AI capabilities integrated within approved NDUS CTS (Core Technology Services) or VCSU Enterprise Systems that may contain private, restricted, or confidential data provided all other provisions of this policy are met.* As of September 26, 2024, approved systems qualifying for this exception include the following:
- Anthology Blackboard and Microsoft Copilot within the Microsoft 365 environment which is a subscription service with a monthly fee.
- Additionally, the free enterprise version of Microsoft Copilot within Bing or Chrome may be used to enter student assignments (private data per FERPA) PROVIDED the enterprise version is used. The enterprise version typically requires the user to enter their NDUS credentials. The attachments, prompts and Copilot replies are not shared with other users or used to train the AI model. There is a non-enterprise version that does not require a user to enter their NDUS credential and entry of private, restricted or confidential data is prohibited when using this version. To ensure you are using the enterprise version of Copilot two things must be present: 1. Your picture, name or initials will appear in the upper right corner of the main window banner that begins with the Microsoft logo on the far left, and 2) a shield symbol that states, "Enterprise data protection..." when hovered over or read by a screen reader will be present immediately below the main banner. If a user is not absolutely certain they are using the enterprise version of Copilot, private data shall NOT be entered.
c. Will you require another employee or student to use a particular AI System to perform an AI query?
If Yes, the system must be an approved VCSU or NDUS System or you need to request permission to Implement the system per section 2 immediately below. As of September 26, 2024, approved systems qualifying for this exception include Anthology Blackboard and Microsoft Copilot within the Microsoft 365 environment or Microsoft Copilot within Bing or Chrome. NOTE: This response does not restrict an employee or student from using their preferred AI System within the guidelines of this policy including adhering to restrictions on entering private, restricted or confidential data - however, one user may not require another user to use a specific AI system that has not been approved by VCSU and Legal Counsel. For instance, a faculty member might require students to use an AI System to complete an assignment with instructions that the enterprise version of Copilot that requires the use of NDUS credentials to gain access is recommended to ensure their assignment is kept private, but students may choose to use a different AI system to complete the assignment.
2. Implement a new software, web site or web service that includes AI capabilities.
a. Complete the One Stop form titled, Request to Use New Software, Web Site or Web Service.
b. If the software includes a significant AI component, the AI Review Board will be consulted and there may be follow-up questions and additional approvals required.
3. AI Project: develop, implement, or improve an AI system
All VCSU AI projects must undergo a review to ensure compliance with this policy and AI Review Board approval is required. There is one exemption to this requirement: A student created AI project as part of a course requirement is exempt, provided all of the following requirements are met:
a) The AI project does not include information classified as private, restricted or confidential by policy, procedure or law;
b) the project will not result in an AI system used for official VCSU business;
c) the project will not be published or presented publicly;
d) the course instructor provides guidance and oversight of the student AI project.*
Definitions
• AI Query: An AI query typically refers to a single interaction or request made to an existing AI system. It involves posing a question or providing input to obtain a specific output or response. AI queries are generally straightforward and do not encompass the entire process of developing or implementing an AI system.
• AI System: A computer-based system that utilizes algorithms, machine learning, or other techniques to perform tasks that typically require human intelligence, such as problem-solving, decision-making, language understanding, and pattern recognition.
• AI Project: An AI project is a comprehensive undertaking that aims to develop, implement, or improve an AI system. It involves multiple components, such as problem definition, data collection, algorithm development, model training, testing, deployment, and ongoing maintenance.*
C. How Do I Submit an AI Project or AI Query for Review?
AI projects and AI queries requiring review and approval shall be submitted to the Chief Information Officer* using the AI Project / AI Query Request form found in the VCSU One Stop. Requests to implement a new AI System must be submitted using the Request to Use New Software, Web Site or Web Service form found in One Stop.
D. How do I Submit a Complaint, Grievance or Appeal?
a. Individuals wishing to report a violation of this policy may contact the Chief Information Officer via email with the subject line “V1203.03 Violation.”* Explain the issue in your own words. Include enough detail so another person can attempt to replicate the issue or otherwise verify what you have stated, e.g. AI tool and version used, exact prompt you used, etc. File attachments are welcome. *The Chief Information Officer shall work with the AI Review Board to respond to the reported violation.*
b. An employee or student who disagrees with the decisions or approval requirements of the AI Review Board concerning a project or query they have submitted for review may request a meeting with the AI Review Board to appeal the decision or approval requirements. The AI Review Board will make a final decision or final approval requirements within 7 business days of the appeal meeting. AI Review Board decisions or approval requirements following an appeal meeting are not appealable.*