AI Policy

Purpose & Scope

This policy sets out the basis on which Clíste Consultants Limited, located at 4th Floor, 11 Anglesea Street, Ballintemple, Cork, Ireland (collectively referred to as “Cliste”, “we”, “us”, “our” or the “Company”), uses artificial intelligence (“AI”) technologies in connection with our business operations, hospitality management and advisory services, and communications.

Cliste recognises the potential for AI technologies to support and enhance the delivery of our services and is committed to ensuring that such technologies are used responsibly, transparently and with appropriate human oversight. Our use of AI is governed by applicable Irish and European Union law, including, where relevant, Regulation (EU) 2024/1689 laying down harmonised rules on artificial intelligence (the “EU AI Act”), the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the Data Protection Acts 1988 to 2018.

This policy is intended principally to provide transparency regarding Cliste’s use of AI and the safeguards that apply to that use. It should be read alongside our Privacy Policy and other applicable data protection and information security policies.

Nature of Usage 

Cliste may use AI enabled technologies in support of our business operations and the services we provide to clients and managed properties. Such technologies may be used to assist with research and analysis, commercial and operational insights, marketing and digital activities, content and communications, administrative processes and other appropriate business functions.

AI is used to support, rather than replace, the professional judgement of our employees and advisers. The extent of human oversight applied will depend on the nature, purpose and potential impact of the relevant use. Where AI assists in the preparation of material professional advice, recommendations or external communications issued by Cliste, appropriate human review and verification will be applied. Cliste remains responsible for the services, advice and communications it provides, notwithstanding the use of AI in supporting their preparation or delivery.

Transparency and Disclosure

Cliste is committed to complying with the transparency requirements applicable to our use of AI under the EU AI Act.

Where Cliste deploys an AI system that interacts directly with an individual, including through an AI enabled chatbot or conversational interface, the individual will be informed that they are interacting with an AI system where such disclosure is required by applicable law. Any required disclosure will be made in a clear and accessible manner and at an appropriate point in the interaction.

Cliste will similarly comply with applicable transparency requirements relating to AI generated or manipulated content where those requirements apply to the particular content and the circumstances in which it is used.

The use of AI as an internal assistive tool, including for research, analysis, drafting or administrative purposes, will not necessarily require disclosure in every instance. Cliste will determine the appropriate level of transparency by reference to the nature of the AI system, the manner in which it is being used and the requirements of applicable law.

Human Oversight and Decision Making

Cliste does not regard AI generated output as a substitute for professional judgement. Employees remain responsible for considering the accuracy, relevance and appropriateness of AI assisted outputs before relying upon them in the course of their work.

Cliste does not use AI to make solely automated decisions that produce legal effects concerning an individual, or similarly significantly affect an individual, except where such processing is permitted by applicable law and appropriate safeguards have been implemented.

AI systems must not be used for any practice prohibited under the EU AI Act or other applicable law.

Data Protection, Confidentiality and Information Security

The use of AI by Cliste is subject to the same obligations concerning personal data, confidentiality, information security and professional responsibility that apply to our other business activities. Personal data, confidential client information, commercially sensitive information or other protected information must not be entered into publicly available or otherwise unapproved AI systems. Where Cliste approves an AI system for the processing of such information, its use will be subject to appropriate technical, organisational, contractual and data protection safeguards, having regard to the nature of the information and the proposed processing. Where personal data is processed through an AI system, Cliste will comply with its obligations under GDPR and the Data Protection Acts 1988 to 2018. Depending on the nature and circumstances of the processing, Cliste may act as a data controller or data processor and will comply with the obligations applicable to it in that capacity. Where appropriate, Cliste will also consider the data protection and information security practices of third party AI providers, including how information submitted to those systems is processed, retained and protected. Further information on how Cliste collects, uses and protects personal data, together with information on data subject rights, is available in our Privacy Policy.

Accuracy and Reliance

AI systems may produce outputs that are inaccurate, incomplete, outdated or otherwise unsuitable for the purpose for which they are generated. Cliste, therefore, requires appropriate human review of AI-assisted outputs, having regard to the nature and significance of the relevant use. Internal procedures and policies are in place, with adherence required by all colleagues of Cliste, in order to meet human review standards in all produced works. Nothing in this policy alters the terms on which Cliste provides professional or advisory services to its clients, including any contractual provisions governing the scope of those services, reliance on advice or limitation of liability.

Amendments 

We reserve the right to amend this policy at any time. Cliste will keep our use of AI and the governance arrangements applicable to that use under review, having regard to developments in AI technology, applicable legislation, regulatory guidance and the nature of the services provided by the business.

Contact

Questions, comments, requests and complaints regarding this Policy and the usage of Artificial Intelligence by Cliste Hospitality are welcome and should be addressed to us at info@clistehospitality.ie or:

Clíste Consultants Limited
4th Floor, 11 Anglesea Street
Ballintemple
Cork
Ireland
T12 CYR8