By the Office of Innovation and Information Technology, Effective 2023
Artificial Intelligence Technologies - Technologies that focus on creating systems capable of performing tasks that typically require human intelligence, such as learning, reasoning, problem- solving, and language understanding, including Generative Artificial Intelligence Tools.
Generative Artificial Intelligence Tools - Technology that can autonomously produce new content, such as images, text, or code (e.g., OpenAI's Chat-GPT, Google Gemini., Dall-E) including search engines and chatbots that leverage A.I. in delivering results.
Artificial Intelligence (“A.I.”) is a powerful and transformative technology that can be utilized to advance NSU’s mission by enhancing efficiency, innovation, and problem-solving, however it is not without risks. As such, any implementation or usage of A.I. by the University or in carrying out University business requires institutional oversight and governance. This policy is intended to establish guidelines and principles for the responsible use and governance of A.I. technology and generative A.I. tools across Nova Southeastern University (NSU). It aims to ensure that A.I. technologies are employed ethically, transparently, and in compliance with relevant laws and regulations, while fostering innovation, research, and educational opportunities.
A. A.I. Technologies Implemented by or on behalf of NSU
The usage and implementation of A.I. technologies by or on behalf of NSU must be done in compliance with all applicable University policies and procedures.
Any data collected and used for A.I. purposes must adhere to data protection, copyright, and privacy laws, including but not limited to the Florida Information Protection Act (“FIPA”), the Family Education Rights & Privacy Act (“FERPA”), the Health Insurance Portability and Accountability Act (“HIPAA”) and other local, state, or federal laws, as applicable.
The use of A.I. tools by or on behalf of NSU in conducting University business is subject to the prior written approval from the NSU Office of Innovation and Information Technology (“OIIT”).
B. Data/Information Security
Many A.I. technologies collect and retain data submitted in furtherance of training and improving their models. As such, the entering or disclosure of Sensitive/Restricted Information (as defined in the NSU Personally Owned Devices Policy) or any other nonpublic/private information into any A.I. tool or technology is prohibited without prior review and approval by OIIT.
The above restriction applies both to A.I. technologies and tools that may be deployed within/on behalf of NSU and NSU personnel as well as any that may be used by external parties while involving NSU personnel. For example, an external vendor that chooses to use an A.I. assistant technology to automatically generate a transcript of an online meeting would be considered an A.I. tool under the scope of this policy.
If an external entity attempts to make use of an unapproved A.I. tool when interacting with NSU personnel, the NSU personnel should immediately discontinue the activity in which the unapproved A.I. tool is involved and notify OIIT. The external party should be advised that NSU does not permit the use of unknown/unapproved A.I. tools and alternative arrangements should be provided to facilitate any future interactions with the external party that will specifically exclude the use of unapproved A.I. tools.
This policy applies to the usage of A.I. tools and technology across all business and academic units, and to all employees, faculty, and staff. This policy does not apply to the use of A.I. tools by NSU employees in their personal capacity for uses unrelated to university business and/or University data.
Individuals or units seeking approval to utilize an A.I. technology or tool should initiate their request through the OIIT Project Intake process, by completing the Project Intake request form, which can be found at https://www.nova.edu/oiit/project-intake.html. OIIT will collect relevant information about the intended use of the A.I. technology or tool and evaluate whether such use is appropriate based on the nature of the data/information exchanged, the privacy/security posture of the tool or technology itself, and any other factor deemed relevant by NSU OIIT. If approved, OIIT reserves the right to establish limitations or restrictions on said usage and may rescind approval at any time.
If you would like further information on the NSU Artificial Intelligence Governance Policy, or have additional questions, please contact us via email to the Office of Innovation and Information Technology point-of-contact at AIGovernance@nova.edu.
All employees having roles or responsibilities covered under this policy are expected to be thoroughly familiar with the policy and its procedures and obligations as they pertain to the employee’s role. Failure to comply with this policy may result in disciplinary action pursuant to all applicable university policies and procedures.