Interwoven Arts uses artificial intelligence in two distinct ways. The first is in the work: the CIC36 declares the company will “leverage advances in artificial intelligence to research, extend accessibility, enhance responsiveness” in its installations — part of the artwork and its accessibility, currently in active research and development ahead of the first installation. The second is in management: an AI administration assistant used in the running of the organisation, operational now.
This note governs the second. There is no CIC-specific regulation of AI in management, so the company holds it to the general law: the directors’ duties under the Companies Act 2006 and UK data protection law.
In plain terms
The AI assistant is the company’s administrative backbone. It maintains registers and the compliance calendar, drafts documents and correspondence, prepares meeting papers and decision records, researches funding and sector developments, and flags deadlines and risks in advance.
It does not make decisions. It prepares information, sets out options, and carries out actions the directors have agreed. It never authorises spending, signs a contract, makes an employment or safeguarding decision, or sends a communication to a beneficiary without a director’s approval.
Accountability stays with the directors. The AI is a tool; every decision is a human decision, and the directors can override it at any time. The company can operate without it.
The legal and regulatory basis
- Independent judgement (Companies Act 2006, s.173). Directors must exercise their own judgement. AI may inform a decision but cannot make one; the judgement remains the directors’.
- Care, skill and diligence (s.174). Using AI to prepare and analyse supports this duty; it does not discharge it. The directors remain responsible for the quality of decisions.
- Decision boundary. The assistant’s defined role is to prepare information, present options, and carry out agreed actions — not to make decisions for the directors, and not to substitute for professional legal, financial, or tax advice. Strategic and governance decisions remain the collective responsibility of the board.
- Records and audit. AI work products, and the reasoning behind them, are auditable; where judgement is applied, the basis is stated. Decisions taken on AI-prepared analysis are recorded with both the analysis and the directors’ decision.
- Verification. AI outputs that inform a decision are checked against their source before they are relied on, so the directors act on confirmed information.
- Data protection. The company is the data controller. AI providers processing its data do so as processors under data processing agreements; processing is recorded in a Record of Processing Activities, and the company registers with the ICO as its processing requires. Special-category data — such as health or safeguarding information — is processed only on an Article 9 UK GDPR basis with the additional safeguards the law requires. Any decision affecting a beneficiary is made by a person and is explainable by a person.
- Disclosure. The company’s use of AI is disclosed through its annual CIC34 and its transparency layer (see reporting & transparency).
- Override and continuity. Director override is always available, and the company is not dependent on the AI to meet its statutory obligations.