Responsible AI for Charities

AI governance and funder accountability

Documented AI governance is now linked to fundability. This course produces the policy, risk assessment, accountability map, and supplier due diligence checklist your charity needs to answer questions from trustees, regulators, and funders. Every document is built on the day around your charity's own operations.

Duration: Full day, 7 hours
Delivery: In-house or online
Group size: Up to 15 participants
Price: £1,695 ex VAT per session

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£1,695 ex VAT

Full day (7 hours)

CEOs, operations directors, governance leads, heads of programmes, and staff at infrastructure bodies (community foundations, CVSs) who advise charities on governance.

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The problem this course addresses

Most charities have staff using AI tools. Few have a policy governing that use. The Charity Digital Skills Report 2026 found 79% of charities use AI, but only 15% have updated their risk register to account for AI, down from 23% the year before. Half of all charities have no AI policy at all, rising to 62% among small charities. 44% are taking no action to manage AI risk.

Funders are moving faster: 71% of grantmaking trusts and foundations have an AI policy or are developing one. Only 36% of small charities can say the same (Charity Digital Skills Report 2026). The gap is not intention. Sector guidance tells charities what to produce without providing the means to produce it.

The Charity Digital Code of Practice 2025 says "develop an AI policy" and "carry out a risk assessment". It does not provide either. This course does.

Who this course is for

This course is for CEOs, operations directors, heads of fundraising, governance leads, and senior managers responsible for moving the charity from informal AI use to a documented position. Infrastructure body staff, including CVS staff and community foundation programme managers supporting charities through this, will also find it directly applicable.

The course works best after AI fluency and responsible AI and data protection. Neither is a formal prerequisite.

Right for you if	Not right for you if
Staff are using AI tools without a documented policy	Your charity already has a current, documented AI policy
Funders or trustees have started asking about AI governance	You need a first introduction to AI for all staff
You need the actual documents, not just general awareness	You need operational training for frontline staff and volunteers
One person handles data protection, operations, and AI governance	You need technical AI development or implementation

What participants will be able to do after this course

Draft an AI policy that fits the charity's decision-making chain, from trustees to volunteers
Complete a risk assessment for the charity's own use cases, including beneficiary triage, grant allocation, and safeguarding referrals
Map accountability across trustees, leadership, staff, and volunteers
Run supplier due diligence on AI tools
Identify whether any AI use falls into the EU AI Act high-risk categories (for charities with EU deployment exposure)
Explain the charity's governance position to funders, trustees, and regulators
Recognise where governance gaps put funding at risk

What the course covers

Every delivery is built around the charity's own tools, decision-making chain, and use cases. No two sessions are identical.

AI policy development

The session produces a policy built around the charity's governance structure: trustees, CEO, operational managers, frontline staff, and volunteers. Not a corporate hierarchy.

Risk assessment

Participants work through a risk assessment against the use cases their charity is likely to encounter, including beneficiary triage, grant allocation, donor wealth screening, safeguarding referrals, and fundraising content generation.

Accountability mapping

Most accountability models assume a stable workforce with continuous oversight. Charities work differently. Boards meet quarterly. The workforce turns over by roughly a third each year. One person often carries data protection, operations, and AI governance at the same time. The mapping in this session is designed for that reality.

Supplier due diligence

The Charity Digital Code of Practice 2025 requires supplier due diligence on AI tools but does not explain how to carry it out. The session produces a checklist participants can apply immediately and repeat as new tools are considered.

EU AI Act deployer obligations and provider reclassification risk

Covered with the audience split described in the regulatory section below, including the Article 25(1) risk for charities that fine-tune or rebrand third-party tools.

Funder accountability

What major UK funders have published, what questions they are asking, and why documented governance is becoming a condition of fundability rather than optional good practice.

How the course is delivered

Discovery call

A 30-minute call before the session covers your charity's tools, current AI use, and governance position. This shapes the day.

Bespoke delivery

The full day runs at your charity's premises or online by video call, for groups of up to 15 participants. The same price applies to both formats. Larger teams are accommodated across multiple sessions.

Compliance documentation

Participants receive documented training completion evidence that meets ICO expectations. The four day-end deliverables are produced during the session itself, not promised for later delivery.

What is included

Pre-course discovery call (30 minutes)
Bespoke course materials written for the charity's own tools and policies
A method guide participants use after the course
Documented training completion evidence meeting ICO expectations
All session materials shared with the charity after the course
A follow-up call after the course
Certificate of completion on request, at no extra charge

Produced on the day

A drafted AI policy
A completed risk assessment
An accountability map
A supplier due diligence checklist

All four are built during the session. They are not promised for later delivery.

How this course aligns with UK and EU regulation

Charity regulators

The Charity Commission's April 2024 guidance states that existing trustee duties apply fully to AI decisions. Trustees must ensure human oversight to prevent material errors and must not delegate critical decision-making to AI without reasonable independent checks.

The Fundraising Regulator's December 2025 guidance requires trustee boards to be involved in strategic AI decisions with ongoing oversight. It expects charities to understand how their AI tools use, store, and share data.

The Charity Governance Code 2025 now recommends a technology and AI policy for the first time. The Charity Digital Code of Practice 2025 states charities should conduct risk assessments, take care with sensitive data in AI models, and carry out supplier due diligence. It defines each obligation without providing the policy, the template, or the standard. This course produces all three.

ICO and UK data protection

The Information Commissioner's Office (ICO) expects organisations to maintain documented training programmes, completion records, and assessment evidence under the UK General Data Protection Regulation (UK GDPR) accountability principle. This course produces evidence that meets those expectations. ICO fines reach £17.5 million or 4% of worldwide annual turnover.

The Data (Use and Access) Act 2025 (DUAA)

Where a charity uses AI to make decisions affecting individuals, those individuals must be informed, able to make representations, and able to request human intervention. Meaningful human intervention means a person who can review and challenge the decision, not one who simply approves it. This applies directly to beneficiary eligibility scoring, hardship fund allocation, and safeguarding referrals.

EU AI Act deployer obligations

This section distinguishes between two groups.

For charities with EU exposure (those that serve people in EU member states, or whose AI outputs are used in the EU), the EU AI Act (Regulation (EU) 2024/1689) Article 26 creates obligations for deployers of high-risk AI systems.

For UK-only charities with no EU exposure, the Act has no direct UK legal force. It sets the benchmark that UK regulatory thinking is moving toward.

Whether a charity's AI use is high-risk depends on what the system is used for, not which sector the charity works in. Under Annex III of the Act, high-risk uses include: AI used to determine admissions, assign learners to levels, grade, or proctor in formal education or vocational training; AI used to decide eligibility for essential public benefits or services on behalf of a public authority; and AI used to assess risk or evidence in asylum, visa, or migration cases. AI used for drafting, summarising, internal triage, or signposting is not high-risk under Annex III.

The main Article 26 obligations apply from 2 December 2027 for standalone high-risk systems and 2 August 2028 for AI embedded in regulated products. The Digital Omnibus on AI (Regulation (EU) 2026/1744), which deferred them from the original 2 August 2026 date, entered into force on 27 July 2026. Transparency obligations under Article 50 were not deferred and have applied since 2 August 2026.

Penalty exposure for deployer-obligation breaches reaches up to €15 million or 3% of worldwide annual turnover. Charities that fine-tune or rebrand a third-party AI tool can take on full provider obligations under Article 25(1), with the same €15 million or 3% penalty exposure. This risk is not widely understood across the sector.

Evidence and trust

Training is designed and delivered by practitioners with direct experience working with UK charities. Co-founders Ben Sefton and Kane Lukassen lead the team.

Insightful AI is listed on the UK Register of Learning Providers. UK Provider Reference Number (UKPRN) 10098807.

The course addresses the gap the Charity Digital Code of Practice 2025 leaves open. The Code says "develop an AI policy" without providing one. It says "carry out a risk assessment" without a template. This course produces both, built around the charity's own operations.

What major UK funders have published

The National Lottery Community Fund published guidance on AI use in funding applications and ten organisational AI principles (January 2025). Applicants will not be rejected for using AI, but the Fund warns that AI produces generic or inaccurate content and expects applicants to edit outputs to reflect their own voice and evidence.

Lloyds Bank Foundation for England and Wales published an AI position statement (updated November 2024). Every application is read by people, not AI. The Foundation warns that over-reliance on AI produces generic applications.

BBC Children in Need updated its A to Z eligibility guidance in February 2026. It will not reject applications for using AI, but may ask whether AI was used during assessment. Applicants must not use AI tools during safeguarding or assessment calls.

Esmée Fairbairn Foundation published AI principles in January 2025. These cover how the Foundation uses AI in its own funding processes. Esmée's published position is about its own operations, not a set of rules for applicants.

Community foundations and regional funders, including Leeds, Surrey, Kent, and Barnwood, have published applicant AI guidance through 2024 and 2025. The consistent expectations are transparency, data protection, authentic organisational voice, and human decision-making.

Governance is now linked to fundability.

Where this course fits

This course sits within the Responsible AI for Charities programme, Insightful AI's six-course training track for the charity sector. It is the senior governance course and pairs with AI for trustees and charity leaders: this session produces the governance position; the trustees course gives the board the legal duties context to approve and oversee it.

The recommended sequence is AI fluency first, then responsible AI and data protection, then this course. Once the policy is in place, safe use of AI in your charity provides the operational layer for staff and volunteers.

Frequently asked questions

What will we leave the day with?

Four documents, all produced during the session: a drafted AI policy, a completed risk assessment, an accountability map, and a supplier due diligence checklist. All four are built around your charity's own tools and operations. They are produced on the day, not promised for later delivery.

How is this different from the responsible AI and data protection course?

The responsible AI and data protection course covers DPIAs, lawful basis, and what data can go into AI tools. This course covers policy development, accountability mapping, supplier due diligence, funder requirements, and EU AI Act deployer obligations. The two courses address different regulatory obligations and work well taken together.

Does this apply to a charity our size?

The Charity Governance Code 2025 now recommends a technology and AI policy for the first time. Funders are asking about governance regardless of size. 76% of organisations have one person or fewer responsible for data protection (ICO Data Controller Study 2024). This course is built around that reality.

Which funders are asking about AI governance?

The National Lottery Community Fund, Lloyds Bank Foundation, and BBC Children in Need have all published positions. Community foundations across the sector, including Leeds, Surrey, Kent, and Barnwood, have published applicant AI guidance through 2024 and 2025. The consistent expectations are transparency, data protection compliance, authentic voice, and human decision-making.

Do we need to comply with the EU AI Act as a UK charity?

That depends on whether the charity has EU exposure. For charities that serve people in EU member states, or whose AI outputs are used in the EU, Article 26 of the EU AI Act (Regulation (EU) 2024/1689) creates deployer obligations. For UK-only charities, the Act has no direct UK legal force. High-risk classification depends on what the AI system is used for under Annex III, not which sector the charity works in.

How much does it cost, and is it priced per person?

The course costs £1,695 ex VAT per session, covering up to 15 participants. The price applies whether the session runs in-house or online. Travel expenses are added for in-person delivery. A programme discount of 10 to 15% applies when three or more courses are booked together.

Who delivers the course, and do they understand charities?

Training is designed and delivered by practitioners with direct experience working with UK charities. Co-founders Ben Sefton and Kane Lukassen lead the team. Every session is built around your charity's own tools and operations.

How long is the course and how is it delivered?

The course runs for a full day (7 hours). It is delivered either in-house at your premises or online by video call. The pre-course discovery call takes 30 minutes and shapes the day. Both formats cover the same content at the same price.

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