Responsible AI in Training
Policy & Governance Framework

Website Visitors, Account Holders, Learners, Purchasers and Corporate Training Participants
NKO Training FZE
Effective date: 15 September 2026 | Version 1.0
Corporate detail Information
Legal entity NKO Training FZE
Trade Licence No. 4429525.01
Formation No. 4429525
Licensing authority Sharjah Publishing City Free Zone Authority
Registered address Business Centre, Sharjah Publishing City Free Zone, Sharjah, United Arab Emirates
Privacy contact booking@nkotraining.com
Telephone +971 52 401 1165
This framework establishes NKO Training FZE requirements for responsible use of artificial intelligence (AI) in the design, delivery, assessment and administration of training. It is intended to support evidence of governance and operational controls. It does not by itself constitute legal advice. NKO Training FZE remains responsible for verifying applicable laws, contractual requirements and accreditation criteria before implementation.

1. Who We Are and Scope

NKO Training FZE is committed to using AI in ways that improve learning quality and operational effectiveness without compromising accuracy, fairness, privacy, professional judgement or learner welfare. AI is a support tool; accountability remains with NKO Training FZE and its authorised personnel.
This framework applies to employees, trainers, facilitators, course developers, assessors, quality reviewers, contractors, freelancers and third parties who use AI on behalf of NKO Training FZE. It covers course research and design, learning materials, images and media, learner communications, assessments, marking support, feedback, analytics, administration and any AI-enabled feature within the learning management environment.
For this framework, AI includes generative AI, machine-learning systems, AI-enabled assistants, automated recommendation or personalisation systems, transcription/summarisation tools and other systems that generate, transform, classify, rank or infer content or decisions. “Material AI use” means AI use that substantially contributes to learner-facing content, assessment, feedback, personalisation or a decision affecting a learner.

Core Principles

  • Transparency: Learners and clients receive meaningful information about material AI use.
  • Accuracy: AI outputs are verified before reliance or publication.
  • Fairness: AI use is reviewed for bias, discrimination and accessibility impacts.
  • Privacy: Personal, confidential, and sensitive information is protected.
  • Human accountability: Qualified people retain responsibility for educational and consequential decisions.
  • Learner-centred use: AI must enhance learning and must not undermine meaningful participation, safety or trust.

2. AI Transparency Policy

2.1 Purpose

To ensure AI-assisted training materials and outputs used by NKO Training FZE are accurate, evidence-based, reliable, and appropriately reviewed before use.

2.2 Scope

This policy applies to all NKO Training FZE employees, trainers, facilitators, course developers, assessors, moderators, contractors, and other persons who use or oversee artificial intelligence in the design, development, delivery, administration, or assessment of NKO Training FZE training activities.

2.3 Policy Statement

AI-generated information can be incomplete, outdated, or fabricated. NKO Training FZE therefore requires evidence-based human verification before substantive AI-assisted content is released or relied upon.

2.4 Roles and Responsibilities

  • Management: Approve this policy, provide resources, oversee compliance, and ensure material risks are addressed.
  • Policy / Quality Owner: Maintain the policy, supporting records, and review cycle; coordinate incidents and corrective actions.
  • Trainers / Course Developers: Use only approved AI tools, apply required controls, retain evidence, and escalate concerns.
  • Reviewers / Assessors: Verify substantive AI-assisted content, confirm sources, challenge unsupported claims, and approve only content that meets NKO Training FZE quality requirements.
  • All Personnel: Complete required awareness/training and report suspected errors, bias, privacy issues, unsafe outputs, or policy breaches promptly.

2.5 Mandatory Requirements

  • All factual claims, statistics, legal or regulatory statements, technical instructions, and references produced or transformed by AI must be checked against credible sources appropriate to the subject.
  • AI-generated citations or links must be independently opened and verified. Invented, inaccessible, or unverifiable references must not be published.
  • Subject-matter review must be proportionate to risk. High-impact, regulated, or safety-relevant subject matter requires review by a suitably competent person.
  • Course materials must have a documented owner and review date. Content affected by changing law, regulation, standards or professional guidance must be reviewed more frequently.
  • AI output must not be treated as authoritative solely because it appears confident, detailed or well written.
  • Material errors discovered after publication must be corrected promptly, and affected learners or clients must be notified where the error could reasonably affect learning outcomes, safety or decisions.

2.6 Operating Procedure

  1. Identify the proposed AI use and confirm the educational or operational purpose.
  2. Confirm that the AI tool is approved for the intended use and that the proposed use complies with this policy.
  3. Apply the mandatory controls in this policy before the AI output is used, published, or relied upon.
  4. Complete appropriate human review and obtain approval proportionate to the risk and learner impact.
  5. Retain the required evidence and record any material issue, correction, escalation, or learner concern.
  6. Monitor the use in practice and revise or discontinue it where controls are ineffective, or risk becomes unacceptable.

2.7 Records and Evidence

  • AI Content Review Checklist
  • Source/reference verification record
  • Correction and version log
Records must be retained in accordance with NKO Training FZE document-control, contractual and applicable legal requirements and must be available for internal review or accreditation evidence where appropriate.

2.8 Breach, Incident and Escalation

Any suspected breach of this policy must be reported promptly to the Policy / Quality Owner or management. NKO Training FZE will contain the issue where necessary, preserve relevant evidence, assess learner and organisational impact, correct or withdraw affected material, notify affected parties where appropriate, identify root cause and record corrective and preventive action.

2.9 Monitoring and Review

Compliance will be monitored through periodic review of AI use records, learner feedback, incidents, content reviews and tool approvals. This policy will be reviewed at least annually and earlier where there is a material change in AI use, technology, law, regulation, accreditation requirements or identified risk.

3. AI Human Oversight and Accountability Policy

3.1 Purpose

To ensure human responsibility, professional judgement and accountability are retained whenever AI supports substantive training outputs or consequential learner decisions.

3.2 Scope

This policy applies to all NKO Training FZE employees, trainers, facilitators, course developers, assessors, moderators, contractors and other persons who use or oversee artificial intelligence in the design, development, delivery, administration or assessment of NKO Training FZE training activities.

3.3 Policy Statement

Human oversight is mandatory for consequential educational decisions and for substantive AI-assisted outputs. Responsibility cannot be delegated to an AI system.

3.4 Roles and Responsibilities

  • Management: Approve this policy, provide resources, oversee compliance, and ensure material risks are addressed.
  • Policy / Quality Owner: Maintain the policy, supporting records, and review cycle; coordinate incidents and corrective actions.
  • Trainers / Course Developers: Use only approved AI tools, apply required controls, retain evidence, and escalate concerns.
  • Reviewers / Assessors: Exercise independent professional judgement, document approval, retain final responsibility, and ensure learners have access to human reconsideration where appropriate.
  • All Personnel: Complete required awareness/training and report suspected errors, bias, privacy issues, unsafe outputs, or policy breaches promptly.

3.5 Mandatory Requirements


  • No course, module, assessment, answer key, certificate decision, or substantive learner-facing material generated or materially assisted by AI may be published without appropriate human review and approval.
  • AI may assist assessment administration or provide draft feedback only where the assessment design permits it and a qualified human retains final responsibility.
  • AI must not independently determine pass/fail, certification, disciplinary action, eligibility, or another consequential learner outcome.
  • Reviewers must be able to challenge, override, or reject AI output and must not treat automation as evidence of correctness.
  • Where AI has materially influenced a decision affecting a learner, NKO Training FZE must be able to explain the human review and provide an appropriate route for reconsideration.
  • The accountable human reviewer must be identifiable in the relevant approval or moderation record.

3.6 Operating Procedure

1. Identify the proposed AI use and confirm the educational or operational purpose.
2. Confirm that the AI tool is approved for the intended use and that the proposed use complies with this policy.
3. Apply the mandatory controls in this policy before the AI output is used, published or relied upon.
4. Complete appropriate human review and obtain approval proportionate to the risk and learner impact.
5. Retain the required evidence and record any material issue, correction, escalation or learner concern.
6. Monitor the use in practice and revise or discontinue it where controls are ineffective or risk becomes unacceptable.

3.7 Records and Evidence

  • Human Review / Approval Record
  • Assessment moderation evidence
  • Decision reconsideration record
Records must be retained in accordance with NKO Training FZE document control, contractual and applicable legal requirements, and must be available for internal review or accreditation evidence where appropriate.

3.8 Breach, Incident and Escalation

Any suspected breach of this policy must be reported promptly to the Policy / Quality Owner or management. NKO Training FZE will contain the issue where necessary, preserve relevant evidence, assess learner and organisational impact, correct or withdraw affected material, notify affected parties where appropriate, identify root cause and record corrective and preventive action.

3.9 Monitoring and Review

Compliance will be monitored through periodic review of AI use records, learner feedback, incidents, content reviews and tool approvals. This policy will be reviewed at least annually and earlier where there is a material change in AI use, technology, law, regulation, accreditation requirements or identified risk.

4. AI Learner Safeguarding Policy

4.1 Purpose

To ensure the use of AI enhances meaningful learning while protecting learners from foreseeable educational, psychological, privacy, integrity and safety risks.

4.2 Scope

This policy applies to all NKO Training FZE employees, trainers, facilitators, course developers, assessors, moderators, contractors and other persons who use or oversee artificial intelligence in the design, development, delivery, administration or assessment of NKO Training FZE training activities. 

4.3 Policy Statement

AI must enhance rather than replace meaningful learning. NKO Training FZE will design AI use to protect learners from foreseeable educational, psychological, privacy and integrity risks.

4. 4 Roles and Responsibilities

  • Management: Approve this policy, provide resources, oversee compliance, and ensure material risks are addressed.
  • Policy / Quality Owner: Maintain the policy, supporting records, and review cycle; coordinate incidents and corrective actions.
  • Trainers / Course Developers: Use only approved AI tools, apply required controls, retain evidence, and escalate concerns.
  • Reviewers / Assessors: Evaluate whether AI use supports learning objectives without displacing necessary human learning activities, and escalate learner welfare or safety concerns promptly.
  • All Personnel: Complete required awareness/training and report suspected errors, bias, privacy issues, unsafe outputs, or policy breaches promptly.

4.5 Mandatory Requirements

  • AI use must not remove essential trainer interaction, practice, reflection, feedback, or other activities necessary to achieve the learning objectives.
  • Learners must have a clear route to contact a human where AI output is confusing, inaccurate, inappropriate, or concerning.
  • AI-generated content must be screened for harmful, inappropriate or unsafe material proportionate to the learner group and course context.
  • AI should not encourage dependency or falsely present itself as a qualified professional. Learners must be reminded to apply appropriate professional judgement in real-world contexts.
  • Concerns raised by learners about AI must be recorded, investigated and used to improve course design and governance.
  • Where an AI feature creates an unacceptable safeguarding risk, its use must be suspended until appropriate controls are implemented and approved.

4.6 Operating Procedure

1. Identify the proposed AI use and confirm the educational or operational purpose.
2. Confirm that the AI tool is approved for the intended use and that the proposed use complies with this policy.
3. Apply the mandatory controls in this policy before the AI output is used, published, or relied upon.
4. Complete appropriate human review and obtain approval proportionate to the risk and learner impact.
5. Retain the required evidence and record any material issue, correction, escalation, or learner concern.
6. Monitor the use in practice and revise or discontinue it where controls are ineffective, or risk becomes unacceptable.

4.7 Records and Evidence

  • Learner concern/complaint record
  • Safeguarding review record
  • Corrective action log
Records must be retained in accordance with NKO Training FZE document control, contractual and applicable legal requirements, and must be available for internal review or accreditation evidence where appropriate.

4.8 Breach, Incident and Escalation

Any suspected breach of this policy must be reported promptly to the Policy / Quality Owner or management. NKO Training FZE will contain the issue where necessary, preserve relevant evidence, assess learner and organisational impact, correct or withdraw affected material, notify affected parties where appropriate, identify root cause and record corrective and preventive action.

4.9 Monitoring and Review

Compliance will be monitored through periodic review of AI use records, learner feedback, incidents, content reviews and tool approvals. This policy will be reviewed at least annually and earlier where there is a material change in AI use, technology, law, regulation, accreditation requirements or identified risk.

5. AI Ethics, Fairness and Bias Mitigation Policy

5.1 Purpose

To ensure AI is used in a manner that promotes dignity, fairness, inclusion, accessibility and equal learning opportunity and that foreseeable bias is identified and mitigated.

5.2 Scope

This policy applies to all NKO Training FZE employees, trainers, facilitators, course developers, assessors, moderators, contractors and other persons who use or oversee artificial intelligence in the design, development, delivery, administration or assessment of NKO Training FZE training activities. 

5.3 Policy Statement

NKO Training FZE will use AI in a manner that supports dignity, inclusion, fairness and equal learning opportunity.

5.4 Roles and Responsibilities

  • Management: Approve this policy, provide resources, oversee compliance, and ensure material risks are addressed.
  • Policy / Quality Owner: Maintain the policy, supporting records, and the review cycle; coordinate incidents and corrective actions.
  • Trainers / Course Developers: Use only approved AI tools, apply required controls, retain evidence, and escalate concerns.
  • Reviewers / Assessors: Review content and AI-supported processes for fairness, inclusion, accessibility, and inappropriate assumptions, and document material findings.
  • All Personnel: Complete required awareness/training and report suspected errors, bias, privacy issues, unsafe outputs or policy breaches promptly.

5.5 Mandatory Requirements

  • AI-assisted content and examples must be reviewed for stereotypes, discriminatory assumptions, exclusionary language, and unbalanced representation.
  • AI must not be used to make or recommend discriminatory decisions based on protected, sensitive, or irrelevant personal characteristics.
  • Where AI personalisation, ranking or recommendations could materially affect learner opportunity or outcomes, the inputs, logic and potential disparate impacts must be reviewed by a human.
  • Training content should include diverse and context-appropriate perspectives where relevant and must not present uncertain AI output as settled fact.
  • Accessibility must be considered when AI is used to generate text, images, captions, transcripts, quizzes or interfaces.
  • Suspected bias or harmful patterns must be escalated, documented, and corrected before continued use where learner impact may be material.

5.6 Operating Procedure

1. Identify the proposed AI use and confirm the educational or operational purpose.
2. Confirm that the AI tool is approved for the intended use and that the proposed use complies with this policy.
3. Apply the mandatory controls in this policy before the AI output is used, published or relied upon.
4. Complete appropriate human review and obtain approval proportionate to the risk and learner impact.
5. Retain the required evidence and record any material issue, correction, escalation or learner concern.
6. Monitor the use in practice and revise or discontinue it where controls are ineffective or risk becomes unacceptable.

5.7 Records and Evidence

  • Bias / Inclusion Review Checklist
  • Accessibility review record
  • Ethics concern/escalation record
Records must be retained in accordance with NKO Training FZE document control, contractual and applicable legal requirements, and must be available for internal review or accreditation evidence where appropriate.

5.8 Breach, Incident and Escalation

Any suspected breach of this policy must be reported promptly to the Policy / Quality Owner or management. NKO Training FZE will contain the issue where necessary, preserve relevant evidence, assess learner and organisational impact, correct or withdraw affected material, notify affected parties where appropriate, identify the root cause, and record corrective and preventive actions.

5.9 Monitoring and Review

Compliance will be monitored through periodic review of AI use records, learner feedback, incidents, content reviews and tool approvals. This policy will be reviewed at least annually and earlier where there is a material change in AI use, technology, law, regulation, accreditation requirements or identified risk.

6. Data Protection and Privacy Policy

6.1 Purpose

To ensure that learner, client, personnel and business information handled by NKO Training FZE is collected, used, stored, shared and disposed of lawfully and securely, including when artificial intelligence is used in training activities.

6.2 Scope

This policy applies to NKO Training FZE employees, trainers, facilitators, course developers, assessors, moderators, contractors, freelancers, and suppliers who handle information or use AI on its behalf. It covers course design, delivery, assessment, learner support, administration, and AI-enabled features within learning systems, including digital and paper records.

6.3 Policy Statement

Learner, client and business data must be handled only for defined, authorised purposes and protected from unauthorised access, disclosure, loss or misuse. Use of AI does not reduce NKO Training FZE’s data protection responsibilities. Only approved AI tools may be used where organisational, learner or client information is involved.

Personal data includes information that identifies or can reasonably identify an individual. Anonymisation must prevent reasonable identification; pseudonymised information remains personal data where it can be linked back to a person.

6.4 Roles and Responsibilities

  • Management: Approve this policy, provide resources, designate a privacy contact, and confirm applicable legal, contractual, and accreditation requirements, including any requirement to appoint a Data Protection Officer.
  • Policy / Privacy Owner: Maintain processing records, privacy notices, retention arrangements, and the review cycle; coordinate privacy requests, supplier assessments, incidents, and corrective actions.
  • Management retains this responsibility until it assigns an owner.
  • AI Governance Lead: Maintain the Approved AI Tools Register and coordinate privacy risk assessments, permitted data restrictions, and approval of proposed AI uses.
  • Trainers / Course Developers: Use approved tools, minimise data inputs, protect learner and client information, retain required evidence, and escalate concerns.
  • Reviewers / Assessors: Protect assessment records, check AI-assisted outputs for inappropriate disclosure, and retain human responsibility for consequential learner decisions.
  • All Personnel: Follow confidentiality and security requirements, complete awareness training, and report suspected privacy or security incidents immediately.

6.5 Mandatory Requirements

  • Identify and document the purpose and lawful basis or applicable authorisation before processing personal data. Collect only the information necessary and keep it accurate.
  • Provide clear privacy information explaining the data used, purposes, recipients, retention criteria, relevant overseas processing, rights, and the privacy contact route. Explain material AI processing and access to human support.
  • Where consent is required, obtain and record it for the specific purpose and provide a withdrawal route. Review marketing, tracking, recording and transcription activities before activation.
  • Do not enter personal data, confidential client information, assessment records, credentials, financial information or other sensitive information into public or unapproved AI tools.
  • Minimise the data you supply to approved AI systems. Use anonymised or fictional information wherever feasible; store any pseudonymisation key separately. Tool approval must specify permitted purposes and data categories.
  • Review supplier terms, data location and transfers, retention, model training use, access controls, subprocessors, deletion options and security assurances before approval. Do not use learner or client information for model training or fine-tuning without a documented basis, risk assessment and management approval.
  • Restrict access to authorised personnel who need it. Use approved accounts, secure sharing, strong passwords, multi-factor authentication where available, and appropriate encryption. Remove access promptly when a role or engagement ends.
  • Assess suppliers and overseas hosting or access before sharing data. Record responsibilities, appropriate contractual safeguards and any applicable transfer mechanism or authorisation.
  • Maintain a retention schedule with justified periods or review triggers. Securely delete or irreversibly anonymise expired records, including exports and supplier copies, subject to documented legal holds and backup expiry arrangements.
  • Log privacy requests, verify identity proportionately and respond securely within applicable deadlines. Explain any restriction or refusal and the available complaint route. Protect other people’s information when responding.
  • Complete a privacy risk assessment before materially new AI processing, sensitive data use, profiling or monitoring. Complete any legally required impact assessment and resolve unacceptable risks before use.
  • Retain qualified human responsibility for pass or fail, certification, disciplinary and eligibility decisions. Provide a route to human review where AI materially influences a learner outcome.
  • Report suspected privacy or security incidents immediately. Preserve evidence and meet applicable regulatory, individual, and contractual notification requirements.

6.6 Operating Procedure

1. Identify the proposed activity, data involved, purpose, applicable basis, and responsible owner.
2. Confirm that the system or AI tool is approved for the intended purpose and data categories; complete supplier and privacy risk checks where needed.
3. Minimise or anonymise the data, apply access and security controls, and provide required notices or obtain required consent before use.
4. Complete human review and obtain approval proportionate to the privacy risk and learner impact before deployment or disclosure.
5. Retain the required records, respond to requests, apply retention and disposal requirements, and report any incident immediately.
6. Monitor the activity and revise, suspend, or discontinue it if controls are ineffective or risks become unacceptable.

6.7 Records and Evidence

  • Approved AI Tools Register and AI Privacy / Data Risk Assessments
  • Processing inventory, privacy notices and consent records where applicable
  • Supplier reviews, processing agreements and overseas transfer assessments
  • Retention schedule, disposal records and access reviews
  • Privacy request log, incident log and corrective action records
  • Policy approvals and personnel training acknowledgements
    Records must be retained in accordance with NKO Training FZE document control, contractual and applicable legal requirements, protected from unauthorised access and available for internal review or accreditation evidence where appropriate.

6.8 Breach Incident and Escalation

Any suspected breach must be reported immediately to the Policy / Privacy Owner or management. NKO Training FZE will contain the issue, suspend affected AI use where necessary, preserve evidence, assess the data and individuals affected, determine required notifications and deadlines, implement corrective action and record closure and lessons learned.

6.9 Monitoring and Review

Compliance will be monitored through reviews of data handling, AI tool approvals, privacy requests, incidents, supplier changes and training records. This policy will be reviewed every six months and earlier following material changes in AI use, technology, law, accreditation requirements or identified risk.

Contact Us

Privacy Contact
NKO Training FZE
Trade Licence No. 4429525.01
Licensed by Sharjah Publishing City Free Zone Authority
Business Centre, Sharjah Publishing City Free Zone, Sharjah, United Arab Emirates
Email: booking@nkotraining.com
Telephone: +971 52 401 1165