FOI Release: Use of AI at RoS

Documents

FOI reference: CW-2025-547
Date received: 5 September 2025
Date responded: 3 October 2025

Information requested:

I would be grateful if you could provide the following detail:

1) AI Systems in use

• A list of tools, platforms or systems currently deployed or being piloted/trialled.
• The purpose and function of each of the above.
• The departments or services where these are operational.

2) Procurement and development

• Details of any contracts, tenders or partnerships with external providers for AI solutions.
• Total expenditure on AI related technologies over the past three financial years, broken down by year.

3) Governance and Ethical Oversight

• Copies of, or information relating to, any internal policies, frameworks or guidance documents relating to the use of AI.
• Any ethical review processes or risk assessments conducted prior to deployment.
• Details of any group responsible for the oversight of AI use within your organisation.

4) Impact on Workforce

• Any assessments, reports or internal communications regarding the impact of AI on staffing levels, job roles or workforce planning (including recruitment, redundancy).
• Information on any roles that have been automated, restructured or made redundant due to AI implementation.
• Details of any training, redeployment or upskilling initiatives offered to staff in response to the adoption of AI.
• Any consultations with trade unions or staff representatives regarding AI-related changes.

5) Performance and Evaluation

• Evaluations, audits or performance reviews of AI systems, as referenced in section 1.
• Evidence of how AI systems have affected service delivery, decision-making or operational efficiency.

6) Data protection and privacy

• Types of data used to train or operate AI systems, including whether this data is synthetic or not.
• Measures in place to ensure compliance with data protection legislation, including the DPA 2018 and UK GDPR.
• Procedures for handling bias, transparency and accountability in AI decision-making.’

Response:

Enclosed is a copy of some of the information you requested. ‘CW-2025-547 RoS AI Technology Summary’ includes high level information relating to the operation of AI systems in RoS.

Further information relating to your questions is provided below:

1) AI Systems in use

• Please see CW-2025-547 RoS AI Technology Summary

2) Procurement and Development

• Please see CW-2025-547 RoS AI Technology Summary

3) Governance and Ethical Oversight

• Copies of, or information relating to, any internal policies, frameworks or guidance documents relating to the use of AI.

RoS AI policies and guidance are still in development. This was discussed at the March 2025 RoS board meeting, minutes of which are published.

• Any ethical review processes or risk assessments conducted prior to deployment.

RoS use of AI has been subject to appropriate risk assessment, encompassing security, data protection and broader AI considerations. Some information from these is contained in CW-2025-547 RoS AI Technology Summary.

After careful consideration, we are withholding the full risk assessments under Section 30(b)(i) and (ii) and (c) of the Freedom of Information (Scotland) Act 2002. This exemption applies where disclosure would, or would be likely to:

• Inhibit the free and frank provision of advice
• Inhibit the free and frank exchange of views for the purposes of deliberation
• prejudice substantially the effective conduct of public affairs

These documents contain detailed assessments of potential risks, vulnerabilities, and mitigations relating to our systems and processes. Disclosure of this information could:

• Discourage staff and stakeholders from providing candid input in future assessments, for fear that sensitive or speculative content may be made public. This would undermine the effectiveness of our internal risk management and decision-making processes
• The release of certain security-related content could compromise operational safeguards, increasing the risk of malicious exploitation
• Undermine the integrity of ongoing or future risk management strategies, especially where these relate to sensitive or evolving AI technologies
• Prejudice the organisation’s ability to manage and respond to data protection risks effectively, particularly where disclosure could expose vulnerabilities or internal deliberations prematurely

We have considered the public interest test and acknowledge that there is a public interest in transparency and accountability. However, in this instance we believe that this interest is outweighed by the need to protect the integrity of our internal deliberations and the security of our systems.

For these reasons, we conclude that the exemption under Section 30(b) applies, and the full risk assessments are being withheld.

• Details of any group responsible for the oversight of AI use within your organisation.

The RoS Artificial Intelligence Working Group (AIWG) exists to review and provide guidance on the responsible and secure use of Artificial Intelligence (AI) technologies within RoS.

The group aims to ensure that AI implementation adheres to the organisation's governance framework, risk tolerance, privacy requirements, information security policies, technical security standards, legal compliance, and ethical principles.

This is an evolving area, and further groups are in development.

4) Impact on Workforce

• Any assessments, reports or internal communications regarding the impact of AI on staffing levels, job roles or workforce planning (including recruitment, redundancy).

RoS AI strategy and implementation is still evolving. At this stage there have been no assessments which focus specifically on the potential impact on RoS workforce. RoS therefore holds no information for this part of your request.

• Information on any roles that have been automated, restructured or made redundant due to AI implementation.

At RoS currently no roles have been automated, restructured or made redundant due to AI.  RoS therefore holds no information for this part of your request.

• Details of any training, redeployment or upskilling initiatives offered to staff in response to the adoption of AI.

Please see CW-2025-547 RoS AI Technology Summary.

• Any consultations with trade unions or staff representatives regarding AI-related changes.

At this stage there have been no AI-related changes that require consultation with trade unions or staff representatives. RoS therefore holds no information for this part of your request.

5) Performance and Evaluation

• Evaluations, audits or performance reviews of AI systems, as referenced in section 1.
• Evidence of how AI systems have affected service delivery, decision-making or operational efficiency.

RoS is at the early stages AI strategy and implementation. As outlined in CW-2025-547 RoS AI Technology Summary, human review of the output from AI is considered as part of the decision-making process. RoS will continue to monitor the impact of AI on the business as it evolves.

6) Data Protection and Privacy

• Types of data used to train or operate AI systems, including whether this data is synthetic or not.

Please see CW-2025-547 RoS AI Technology Summary.

• Measures in place to ensure compliance with data protection legislation, including the DPA 2018 and UK GDPR.

Please see answer to question 3 above and CW-2025-547 RoS AI Technology Summary.

• Procedures for handling bias, transparency and accountability in AI decision-making.’

Please see answer to question 3 above and CW-2025-547 RoS AI Technology Summary.

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