Data Ethics Policy

We will strive to make sure that any use or development of AI solutions are fair, reliable, and explainable.


1.1 Our Approach

We strive to be transparent about our ethical decisions and effort to uphold our ethics principles when processing data. We encourage all employees and business partners to bring forward concerns or improvement proposal that improve our data processes. We will ensure we have the required resources and skills to uphold this policy.

1.2 Overall Data Integrity

We will uphold data integrity in our data actives to ensure data are processed, fair and with proper legal basis and that data minimization principles are enforced.

1.3 Data Processing

We will take measures to ensure our use of data are unbiased and without discrimination,

We will through our Global Information Security Policy ensure that all data not intended for public disclosure are protected accordingly,

We acknowledge the existing of vulnerable groups or individuals for whom some data creates a need for special confidentiality and protection. We will take actions to identity and mitigate risks, where such data would or could exists in our organization.

1.4 Our Solutions

We will take legal and ethics aspect into account when developing new solutions that processes data through a formalized process.

We will ensure diversity when creating user-groups for solution development of systems to process data,

when we bring solutions to the market that processes data, which could be used to:

  • Limit the right to freedom of expression and information or the rights to free elections,
  • Violate data protection rights,
  • The right of privacy and family life,
  • Fair elections, good public administration, access to justice and a fair trial,
  • Creates an disproportional position towards vulnerable groups or individuals
  • Or other unethical use

We will ensure that we can revoke user rights if needed, to the extent such legal remedies are available.

When working with AI, we will have a human-centered society approach in which humans and AI coexist. We will strive to make sure that any use or development of AI solutions are fair, reliable, and explainable.

Action Plan

In support of our data ethics policy, we have identified the activities for the current financial period which will ensure going forward that the policy becomes an integral part of our work with data ethics issues. This is especially true in areas where there is a risk of conclusions based on data containing significant bias, or where there may be a lack of transparency in our data use when making major decisions.

Our data security and compliance is based primarily on our existing ISAE 3402 Type 2 and ISAE 3000 (GDPR) Type 2, independent audit reports. In addition, we are in the process of establishing an ISO 27001 certified program, where we have completed the so-called phase 1 in the current accounting period. We expect final certification no later than the end of the calendar year 2021.

To further ensure a lasting implementation of the policy on data ethics, an internal working group will be set up to ensure continuous and systematic assessment of areas at risk of bias in data, as well as ensure the necessary breadth in test groups where necessary. Until this working group is formed, our Global Ethics Committee will be consulted where necessary. The policy will also be supported by internal campaigns, systems and procedures.

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If you have any questions, please feel free to contact us.

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