AI Policy

Hove Capital Limited builds financial software for fintech, personal finance, and banking. We recognise the significant benefits that artificial intelligence technologies can bring to software development and financial services, while also understanding the importance of deploying such technologies in a secure, controlled, and responsible manner.

This policy outlines our approach to the use of AI within our business and in the software we develop for our clients.

Hove Capital embraces artificial intelligence as a tool to enhance the quality and efficiency of our work. We are committed to using AI responsibly and transparently, with appropriate human oversight at every stage.

We believe AI should be employed to aid and expedite research, assist development workflows, and improve the overall performance of day-to-day activities. AI is not used as a direct, unverified source of truth in any of our deliverables.

Given the regulated nature of financial services, we apply additional scrutiny when using or integrating AI in financial software:

• Code review: All AI-assisted code is subject to the same rigorous review process as manually written code. No AI-generated code is deployed without human review and approval.
• Testing: AI-assisted outputs are tested to the same standards as all other deliverables, with particular attention to edge cases and regulatory requirements.
• Audit trail: We maintain clear records of where AI has been used in the development process to support regulatory compliance and client transparency.
• Client disclosure: We are transparent with our clients about our use of AI tools in the development process.

Any information delivered directly from AI sources must be verified for authenticity and accuracy before it is used in any deliverable. This applies to:

• Code suggestions and generated code
• Technical documentation and specifications
• Research findings and data analysis
• Security recommendations
• Regulatory or compliance guidance

Where AI is used to verify existing work, the verification itself must be independently confirmed before the work is delivered or deployed.

Hove Capital maintains an internal list of approved AI tools and platforms that may be used by staff. The selection of approved tools considers:

• Data privacy and security practices of the AI provider
• Whether data submitted is used to train models
• Compliance with UK data protection legislation
• The tool's suitability for use with sensitive financial data
• Enterprise-grade security features and access controls

Any use of AI tools not on the approved list must be authorised by management prior to use. Sensitive client data, personally identifiable information, and proprietary source code must not be submitted to AI tools unless the tool has been explicitly approved for such use.

When using AI tools, we ensure compliance with the UK GDPR and Data Protection Act 2018:

• Personal data is not submitted to AI platforms without appropriate safeguards and, where required, data subject consent.
• We assess the data processing practices of AI providers as part of our due diligence.
• AI tools that process personal data are included in our data processing records and, where applicable, Data Protection Impact Assessments.
• We ensure that AI-assisted processing of personal data has a valid lawful basis under Article 6 of the UK GDPR.

Hove Capital is committed to aligning with recognised standards for the responsible use of artificial intelligence, including the principles set out in the BS EN ISO 42001 International Standard for Artificial Intelligence Management Systems.

We ensure compliance with all applicable legal and regulatory requirements relating to AI, including those set by the Financial Conduct Authority (FCA) and the Information Commissioner's Office (ICO).

This policy and our AI practices are regularly reviewed to ensure they remain appropriate and effective. Reviews are conducted:

• At regular management review meetings
• When significant changes occur in AI technology or regulation
• When new AI tools or use cases are proposed
• Following any incidents involving AI-related issues

If you have any questions about this AI Policy or how we use artificial intelligence, please contact us:

• Email: [email protected]
• Data Protection Officer: [email protected]
• Telephone: 01273 937117
• Address: Curtis House, 34 Third Avenue, Hove, BN3 2PD

Hove Capital Limited, registered in England, company number 13049782.