Scottish Canals (the data controller) may use Artificial Intelligence (AI) tools to support our work and improve services. The primary AI tool is Microsoft Copilot, which works within everyday software, including the Microsoft 365 Suite including Teams, Word and Outlook. This helps staff work in an efficient manner while keeping information safe and secure. Some examples may include helping create presentations, writing notices or analysing spreadsheet data. It may also be used to create transcripts and action plans from meetings. 

Personal data may be processed when our staff use AI tools in support of their work and the delivery of services. Data may relate to: 

• Members of the public
• Customers and service users
• Partner organisation staff or representatives
• Council and elected staff
• Anyone working within Scottish Canals' premises (for example sub-contractors, consultants, etc.)

The type of personal data may be dependent on the type of work being carried out. Any processing using AI will be within the scope of purposes for which the data was initially collected. This may include:

• Names
• Contact details and addresses
• Customer reference numbers
• Notes or summaries of meetings
• Information about services received or cases

Since the use of AI tools is not in collection of new personal data, we rely on the original lawful bases for which the data was collected. In most cases this will be:

• Legitimate Interests (Article 6(1)(f))
• Public Task (Article 6(1)(e))
• Contract (Article 6(1)(b))
• Legal Obligation (Article 6(1)(c))

AI is not used to support, not replace, human judgement. It is not being used to make decisions about service users, customers or stakeholders. Microsoft or related IT (AI) providers are data processors who use the personal data as instructed by the data controller and for no other purposes. Processing is carried out under strict contracts and security standards as per data protection regulations. It is not used to train or improve Microsoft or Third Party AI models. We acknowledge that the potential use of AI tools, including Copilot, may evolve over time. New applications will be considered and must align with our privacy and security frameworks. 

Date last updated: 21 August 2025