AI Governance Policy

1. Scope

This policy governs the use of AI systems by 121 Group Pty Ltd in delivering services to clients. It applies to every AI-augmented output we produce, content drafts, ad creative variants, video, copy, analytics, dashboards, and operational tooling.

2. The principle

Every AI-generated output that affects, refers to, or could be seen by a person is human-reviewed by a senior strategist before it ships. AI is the production multiplier. The senior strategist remains the quality bar and the accountable party.

3. Where AI is deployed

• Gemini 2.0, strategy synthesis, brief expansion, long-form content drafting, NL2SQL for analytics
• Imagen 3, brand-trained ad creative variant production
• Veo 3, short-form video at retainer cadence
• Vertex AI, analytics pipelines, attribution modelling, audience clustering
• BigQuery, portfolio reporting, multi-brand consolidation

4. What we will not do

• We will not use client-confidential or patient personal information to train any general-purpose AI model
• We will not ship AI-generated regulated content (healthcare, financial, legal claims) without the relevant compliance review
• We will not publish AI-generated likenesses of identifiable real people without their consent
• We will not use AI to fabricate testimonials, reviews, statistics or case-study claims
• We will not ship AI-generated content that misrepresents itself as authored by a specific human (e.g. attributed to a clinician who did not author or approve it)
• We will not deploy autonomous AI agents to take final external-facing actions on behalf of a client (publishing, sending, transacting) without a human approval step

5. The review pipeline

Every AI-generated output passes through one or more of the following review gates before it ships:

• Senior strategist edit, substantive editorial review on every long-form piece
• AHPRA review, for healthcare creative, content and clinical claims
• Procurement claim review, for industrial capability statements and tier-1 panel collateral
• Australian Consumer Law claim review, for consumer-brand creative making product or comparative claims
• Founder pass, for consumer brands where the founder voice is a brand asset
• Client approval, for any output the client has reserved sign-off on

6. Provenance and audit trail

For our regulated clients, every output carries provenance metadata: which model generated it, which prompt produced it, who reviewed and approved it, when it was published. Available on request for any client.

7. Data residency and isolation

AI processing of client data occurs within our private Google Cloud / Vertex AI environment, with data residency in australia-southeast1 where the model and capability supports it. Client data is isolated per engagement, we do not pool client data across accounts for training or inference purposes.

8. Patient and sensitive data

Patient personal information from our healthcare clients is excluded from AI processing at the boundary level. Where a client engagement involves pathology data, patient-record data, or clinical encounter data, we operate under a separate written data handling protocol agreed with that client and their compliance officer.

9. AI-generated likeness and synthetic media

We may use Imagen and Veo 3 to produce ad creative and short-form video. Where the output depicts a person, we use one of: (a) generic, non-identifiable AI-generated likenesses; (b) likenesses of consenting individuals contracted as talent; or (c) brand-owned likenesses of company employees who have consented. We do not produce synthetic media of identifiable real people without their consent.

10. Disclosure to end users

When AI-generated content is published in a context where disclosure is legally required (e.g. AI-generated political content, AI-disclosed marketing in jurisdictions that require it), we disclose. For routine marketing collateral that is human-reviewed and brand-aligned, we follow standard industry practice.

11. Changes to this policy

This policy evolves as AI capability and regulation evolves. We version every revision and keep prior versions available on request.

Contact

For specific questions about how AI is deployed on your engagement, contact your account lead. For policy-level questions:

121 Group Pty Ltd
AI Governance Owner: Adam Ducquet
Email: ai-governance@121group.io