AI Policy

Artificial Intelligence is increasingly becoming part of the technology used to deliver, support and improve telecommunications services.

IQ Mobile embraces AI where it provides a genuine benefit to our customers, partners and employees. We use AI to improve accessibility to support, assist with technical diagnostics, automate repetitive processes and help our team develop and deliver services more efficiently.

We recognise, however, that the use of AI also introduces responsibilities around privacy, security, accuracy, transparency and fairness.

Our approach is therefore based on a simple principle: AI should assist people, not remove accountability from them.

AI systems deployed by IQ Mobile are subject to appropriate technical and organisational controls and are designed to operate only within their intended purpose and authorised access to information.

IQ Mobile currently uses AI across a number of operational and customer-facing services. The nature and level of access provided to an AI system depends on its specific purpose.

Outside normal support availability, including certain lunch periods and when our team is unavailable, telephone enquiries may be answered by an AI-powered voice agent. Our voice AI technology uses ElevenLabs Agents and has been configured and integrated specifically for IQ Mobile.

The agent has been given information about IQ Mobile's products and services and may use approved IQ Mobile information sources to help answer customer enquiries. Where required to provide support, it may also interact with authorised IQ Mobile systems to retrieve limited information relating to a customer's services or SIMs.

Access to customer-specific information is subject to identity verification and appropriate data protection controls — for example, matching the calling telephone number (CLI) and/or information such as the email address held against an account.

The AI agent operates within technical instructions, permissions and guardrails established by IQ Mobile, which restrict the information and actions available to it. Customers are informed when they are interacting with an AI-powered service.

AI support is intended to complement our human support team rather than replace it. Matters that cannot be safely or appropriately resolved through automated support can be referred for human review or follow-up.

Authorised IQ Mobile Channel Partners may have access to AI-assisted diagnostic and support functionality through the IQ Mobile Partner Portal at mobileportal.uk. These capabilities can include assistance with:

• packet capture (PCAP) analysis;
• SIP registration and diagnostic information;
• telecommunications troubleshooting;
• SIM and service diagnostics; and
• analysis of technical information associated with services managed by the Partner.

These tools use Large Language Models and other automated analysis technologies to interpret technical information and assist Partners in identifying potential faults or configuration issues. Access is restricted to authenticated IQ Mobile Partner accounts.

AI tools within the Partner Portal operate within defined permissions and guardrails. A Partner cannot use an AI assistant to circumvent normal portal permissions or intentionally retrieve information belonging to another Partner. AI therefore operates as an additional interface to authorised information, rather than as a mechanism for expanding a user's underlying access rights.

IQ Mobile applies the same data protection principles to AI systems as it does to its wider telecommunications and information systems. Where AI systems process personal data, we consider the requirements of applicable UK data protection legislation, including the UK GDPR and Data Protection Act 2018.

Our approach includes the principles of:

• lawful, fair and transparent processing;
• purpose limitation;
• data minimisation;
• accuracy;
• storage limitation;
• appropriate security; and
• accountability.

Access to personal or customer-specific information is limited to what is reasonably required for the function being performed. AI systems are not provided unrestricted access to IQ Mobile customer or Partner data.

Where appropriate, IQ Mobile assesses the privacy and security implications of new AI implementations before they are introduced, and maintains appropriate contractual and data-processing arrangements with technology providers.

AI services are incorporated into IQ Mobile's wider information security practices. Depending on the system and risk involved, controls may include:

• individual authenticated user accounts;
• role-based and account-based access controls;
• restrictions on the systems and information available to AI services;
• activity and access logging;
• secure credential management;
• appropriate password and authentication controls;
• separation of Partner and customer data;
• AI-specific system instructions and guardrails;
• monitoring and review of AI functionality; and
• human escalation where appropriate.

Shared credentials are not used as a substitute for individual user access where individual authentication is appropriate.

IQ Mobile continually reviews its security practices as the technology and associated threats evolve. We take account of recognised industry good practice and relevant UK guidance, including the principles contained within the UK Government's AI Cyber Security Code of Practice.

Generative AI systems can produce incomplete, inaccurate or unexpected responses. IQ Mobile therefore does not assume that an AI-generated response is correct simply because it has been produced by an automated system.

The level of human oversight applied depends upon the nature and potential impact of the AI system. AI may assist with customer service, diagnostics, technical analysis and internal decision support, but responsibility for IQ Mobile's services and operations remains with IQ Mobile and its people.

Where an issue requires judgement, falls outside the permitted scope of an AI system, or cannot be handled with sufficient confidence, it should be escalated to an appropriate person.

IQ Mobile aims to design and operate customer-facing AI services in a way that is fair, respectful and impartial. We do not intentionally configure AI systems to discriminate against individuals based upon protected or personal characteristics.

Customer-facing AI systems are given defined behavioural instructions and technical guardrails designed to limit inappropriate, harmful or irrelevant responses.

Where AI technology or underlying models are supplied by third parties, IQ Mobile considers the security, privacy and suitability of those suppliers and services before integrating them into our operations.

IQ Mobile sees AI primarily as a tool for increasing the capability of our people. AI is used internally to automate repetitive work, accelerate development, assist with research and troubleshooting, improve access to information and allow employees to concentrate on work where human judgement, creativity and relationships provide greater value.

IQ Mobile maintains a human-first approach to employment and development. Since introducing AI technologies within the business, IQ Mobile has not made roles redundant as a consequence of AI adoption — instead, these technologies have enabled our existing team to work more efficiently and deliver new products and improvements more quickly.

As AI capabilities continue to develop, we intend to continue investing in both technology and the people who use it.

Employees using AI as part of their work are expected to do so responsibly. Confidential, commercially sensitive, customer or personal information must not be entered into unapproved public AI services.

AI-generated content, code, analysis or recommendations should be treated as assisted output rather than automatically assumed to be accurate. Employees remain responsible for work they produce using AI and should apply appropriate human judgement, verification and review before AI-generated material is relied upon or published.

AI technology is developing rapidly and IQ Mobile expects its use of AI to evolve alongside it. New AI systems and significant changes to existing AI implementations are considered from security, privacy, operational and ethical perspectives proportionate to their intended use and associated risk. IQ Mobile may review areas including:

• what information an AI system can access;
• how users are authenticated;
• what actions the AI can perform;
• how personal information is protected;
• whether appropriate logging and monitoring exists;
• how inaccurate or inappropriate outputs are handled;
• whether human escalation is available;
• the security and data-processing practices of third-party AI suppliers; and
• whether the continued use of the system remains appropriate.

AI systems may be restricted, modified or withdrawn where IQ Mobile identifies an unacceptable security, privacy, operational or ethical risk.

IQ Mobile believes AI can make telecommunications services easier to use, easier to support and faster to develop. We also recognise that adopting new technology brings responsibilities.

Our commitment is therefore to use AI in a way that is secure, transparent, proportionate, fair and accountable, while keeping people at the centre of the services we provide.

AI should enable our customers, Partners and employees to do more — not diminish the importance of the people behind IQ Mobile.