Responsible Use of AI

Purpose

The purpose of this policy is to guide the ethical and compliant use of Artificial Intelligence (AI) by ONBOARD LENDING LIMITED, a fully licensed Financial Advice Provider (FAP).

AI may only be used to assist, not replace, regulated financial advice processes.

This policy ensures compliance with:

  • The Financial Markets Conduct Act 2013 (FMCA)
  • The Privacy Act 2020
  • The Code of Professional Conduct for Financial Advice Services

All regulated financial advice must be reviewed and approved by a human adviser. AI tools may not be used to provide unreviewed recommendations or decisions and do not reduce or remove the obligations of the FAP or its advisers.

This policy applies to all employees, contractors, financial advisers, and any representatives using AI in the course of business.

Our Commitment to Responsible AI Use

Ethical Principles

  • Prioritising client interests by ensuring all advice remains human-reviewed and personalised.
  • Maintaining transparency about when AI is used in communications or processes.
  • Holding advisers fully accountable for any advice or client outcomes.

Acceptable AI Uses

  • Drafting client-facing educational content, newsletters, or social media posts (with human sign-off).
  • Generating templates or draft structures for Statements of Advice or needs analyses (subject to adviser review).
  • Summarising meeting notes, documentation, or compliance reports.
  • Supporting internal research or CPD planning.
  • Streamlining administrative processes such as file reviews or policy comparisons.

Prohibited AI Uses

  • Generating unreviewed financial product recommendations.
  • Replacing the six-step financial advice process.
  • Entering personally identifiable client data into unsecured or public AI systems.
  • Using AI to avoid disclosure, compliance, or record-keeping obligations.

Process
Tool Vetting & Approval

All artificial intelligence tools used within the business must be subject to a documented risk assessment prior to use and approved internally by the FAP.

The assessment must consider:

  • Compliance with the Privacy Act 2020.
  • Information security and confidentiality risks.
  • Contractual assurances regarding data handling, retention, and use.
  • Alignment with the FAP’s regulatory obligations.
  • Having regard to any relevant guidance issued by the business’s aggregator.

AI tools that process, store, or analyse business or client data are treated as outsourced service providers and must be assessed and managed accordingly.

Data Protection and Client Confidentiality

All proprietary business data, including internal communications, intellectual property, and client-sensitive information, must not be entered into any non-approved AI platform.

Client information may only be used with AI tools where:

  • The tool operates within a private or enterprise environment.
  • The tool has been formally approved by the FAP.
  • Contractual terms confirm client data is not used for model training or shared outside the service.
  • Data is not retained beyond the purpose for which it is processed.
  • Appropriate access controls and security safeguards are in place.

Regulatory Accountability

The use of AI tools does not remove or reduce the obligations of the FAP under financial services legislation, the Code of Professional Conduct for Financial Advice Services, or any other applicable regulatory requirements.

All advice remains the responsibility of the licensed Financial Advice Provider and authorised advisers.

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