Artificial Intelligence Use Policy

1.  Purpose, Philosophy, and Scope

1.1  Purpose

Every generation encounters a technology that redefines education. For this generation, that technology is artificial intelligence (“AI”). Franklin Global Online LLC, doing business as Franklin Global (“Franklin Global,” “we,” “our,” or “us”), recognizes that its Learners will enter a world in which the ability to use AI critically, ethically, and effectively is a foundational skill, as important as reading, writing, and quantitative reasoning. This Policy exists to ensure that Franklin Global prepares its Learners for that world thoughtfully, responsibly, and without treating AI as something to be feared or avoided. 

This Artificial Intelligence Use Policy (the “AI Use Policy” or “Policy”) establishes Franklin Global’s comprehensive framework for the use of AI and generative tools across all aspects of Franklin Global’s educational programs and operations. It provides specific, practical guidance for each member of the Franklin Global community: Learners, Learning Partners, faculty and staff, and Franklin Global’s administrative team.

This Policy is a companion to Section 4 of Franklin Global’s Acceptable Use Policy (the “AUP”), which establishes the governing rules for AI use across all Franklin Global platforms and technology resources. In the event of any conflict between this Policy and AUP Section 4, AUP Section 4 governs. Defined terms used in this Policy, including “Learners,” “Learning Partners,” “Franklin Global-approved AI tools,” and “unauthorized AI use,” have the meanings given to them in the AUP unless otherwise specified.

1.2  Franklin Global’s AI Philosophy

Franklin Global’s approach to AI is grounded in three foundational beliefs:

AI is a tool, not a substitute for thinking.

Franklin Global’s educational model is built on the development of independent, self-directed thinkers. AI tools are powerful and can accelerate research, scaffold writing, generate ideas, and support learning in meaningful ways. But they cannot replace the intellectual effort that genuine learning requires. A Learner who uses AI to avoid thinking has not learned; they have only produced an output. Franklin Global’s AI philosophy begins and ends with this distinction.

AI literacy is an educational outcome, not just a compliance concern.

Franklin Global does not approach AI governance primarily as a risk management exercise. Franklin Global holds that understanding how AI works, recognizing its limitations and biases, using it transparently and ethically, and knowing when not to use it are skills Franklin Global is responsible for developing in its Learners. This Policy is as much a curriculum commitment as it is a conduct framework.

Transparency and honesty are non-negotiable.

Franklin Global does not prohibit the use of AI tools outright. What Franklin Global prohibits is the use of AI to misrepresent a Learner’s own understanding, to replace original thinking, or to circumvent the learning process. The line is not between using AI and not using AI; it is between honest use and dishonest use. A Learner who uses AI and discloses it is acting with integrity. A Learner who uses AI and conceals it is not.

Franklin Global’s Governing Test for AI Use When a specific situation is not addressed by this Policy, community members should return to these three principles and ask: (1) Does this use help the Learner genuinely learn? (2) Is the use being conducted honestly and transparently? (3) Does it develop rather than replace independent thinking? If the answer to all three is yes, the use is consistent with Franklin Global’s AI philosophy.

1.3  Relationship to the Acceptable Use Policy

This Policy operates as a standalone companion to Franklin Global’s AUP. AUP Section 4 establishes the governing rules and definitions. This Policy expands on those rules with audience-specific guidance, practical direction for common scenarios, and the operational frameworks, including the AI tool vetting process, the approved tools list, and the AI use disclosure template, which give the AUP’s rules practical effect.

This Policy should be read alongside the following Franklin Global policies, all of which are incorporated by reference:

• Acceptable Use Policy (in particular Section 4, Artificial Intelligence and Generative Tools, and Section 5, Academic Integrity)
• Privacy Policy
• Learner and Learning Partner Handbook
• Safeguarding and Child Protection Policy
• Nondiscrimination Statement
• Anti-Bullying and Online Safety Policy

In the event of a conflict between this Policy and any of the above, the more protective or restrictive standard applies.

1.4  Scope

This Policy applies to:

• All Learners accessing any Franklin Global program, course, or platform;
• All Learning Partners who support a Learner’s participation in Franklin Global’s educational programs;
• All Franklin Global faculty and staff in the performance of their educational and administrative duties; and
• Franklin Global’s administrative team in the conduct of Franklin Global’s operations.

This Policy governs the use of AI tools in connection with:

• All academic work submitted as part of any Franklin Global program, course, or learning activity;
• All synchronous and asynchronous learning activities, including dialectic circles, live class sessions, discussion boards, and recorded responses;
• All communications conducted through Franklin Global’s designated platforms;
• All administrative functions performed by Franklin Global faculty, staff, and administrators using AI tools; and
• Any personal device or platform used to access, complete, or submit Franklin Global academic work or to perform Franklin Global administrative functions.

This Policy applies regardless of whether the AI tool used is a Franklin Global-approved tool or a personal tool accessed outside of Franklin Global’s platforms. The governing question is not which tool was used; it is whether the use was authorized, honest, and consistent with this Policy and the AUP.

1.5  International Reach and Applicable Law

Franklin Global serves Learners who may be located across multiple countries. This Policy is designed to align with applicable U.S. federal law, including FERPA, COPPA, and CIPA, to the extent applicable, as well as international frameworks, including GDPR and UK GDPR, where relevant. Where a Learner’s country of residence imposes additional obligations with respect to AI use, data processing, or student privacy, Franklin Global will endeavor to comply with those obligations.

1.6  Policy Review

Given the pace of change in AI technology, Franklin Global commits to reviewing this Policy no less than semi-annually and at the start of each semester, and will update it more frequently if significant changes in technology, applicable law, or educational best practices warrant it. Material changes will be communicated to Learners, Learning Partners, and Franklin Global faculty and staff with reasonable advance notice. The current version of this Policy, including its last updated date, is available at https://franklinglobal.org/artificial-intelligence-use-policy/. 

2. Definitions and Key Concepts

The following definitions apply throughout this Policy and are aligned with the definitions in AUP Section 4.1. Where a term is defined in the AUP and used here, the AUP definition governs.

2.1  Core Definitions

• “Artificial intelligence” or “AI” refers to computational systems that use machine learning, large language models, or other algorithmic processes to perform tasks that typically require human intelligence, including generating text, images, code, audio, video, or other content in response to user inputs.
• “Generative AI” refers to AI systems specifically designed to generate new content, including written text, images, audio, video, and code, based on patterns learned from training data. This includes large language model chatbots, image generators, code completion tools, and AI-powered writing assistants.
• “AI tools” refers to any software, application, or platform that uses artificial intelligence to perform tasks on behalf of a user. This includes both generative AI and non-generative AI tools used in educational or administrative contexts.
• “Franklin Global-approved AI tools” refers to AI tools that have been reviewed and explicitly authorized by Franklin Global for use in a specific educational or administrative context. A list of currently approved tools is maintained in Franklin Global’s Learner and Learning Partner Handbook or as communicated by Franklin Global faculty, and updated periodically through the vetting process described in Section 7.
• “Unauthorized AI use” refers to use of any AI tool, approved or unapproved, in a manner that violates this Policy or the AUP, including submitting AI-generated content as a Learner’s own original work without disclosure, using AI during prohibited assessments, or using unapproved tools where an approved tool has been designated.
• “AI Use Disclosure” refers to the written statement a Learner is required to include when submitting work in which an AI tool was used, identifying the tool, the nature of its use, and how the Learner engaged with or built upon the AI output. The standard disclosure template is provided in Appendix B of this Policy.
• “Shadow Use” refers to the use of AI tools by faculty, staff, or administrators without the knowledge or approval of Franklin Global’s technology or administrative team. Shadow Use that involves student data or Franklin Global systems is a violation of this Policy and the AUP.

2.2  The IB Two-Part Test

Franklin Global adopts the International Baccalaureate’s (“IB”) two-part test as a practical framework for evaluating AI use, particularly for Learners:

The IB Two-Part Test for AI Use (1) Did the Learner use AI to help them learn? If yes, the use is generally acceptable. (2) Did the Learner use AI to pretend they did something they did not? If yes, the use is not acceptable. This test does not replace the specific rules in this Policy and the AUP. It is a practical guide for evaluating ambiguous situations not explicitly addressed by those rules.

The two-part test reflects Franklin Global’s core belief that AI use in service of genuine learning is acceptable, and AI use in service of misrepresenting a Learner’s understanding is not. Faculty and Learning Partners may use this test when evaluating whether a specific use is consistent with Franklin Global’s AI philosophy.

2.3  Categories of AI Use

For clarity throughout this Policy, AI use is categorized as follows:

• Permitted use: AI use that is explicitly authorized by this Policy, the AUP, or a Franklin Global faculty member’s course-level guidance, and that is disclosed in accordance with Section 4.4 of the AUP.
• Conditionally permitted use: AI use that is permitted only when specific conditions are met, such as faculty authorization, prior disclosure, or use of a Franklin Global-approved tool.
• Prohibited use: AI use that is explicitly prohibited by this Policy, the AUP, or a Franklin Global faculty member, regardless of disclosure or intent.
• Unauthorized use: Any AI use that does not fall within the categories of permitted or conditionally permitted use as defined by this Policy, the AUP, or applicable Franklin Global faculty guidance.

3. Guidance for Learners

Franklin Global’s Learners are the primary audience for this section. The guidance here expands on the rules in AUP Section 4 with practical direction tailored to Learners in Grades 6 through 12. Learners should read this section alongside AUP Sections 4 and 5.

3.1  The Learner’s Responsibility

Each Learner is personally responsible for understanding and complying with Franklin Global’s AI use standards. Claiming not to have known that a particular use was prohibited is not a defense to a finding of academic integrity violation. When a Learner is uncertain about whether a specific use is permitted, they must ask their Franklin Global faculty member before proceeding, not after.

The governing principle is simple: AI may be used to help a Learner think, but not to think for them. A Learner’s submitted work must represent their own genuine understanding and intellectual effort, even when AI tools played a role in the process.

3.2  Permitted Uses of AI for Learners

The following uses of AI are permitted for Learners, subject to any course-specific guidance provided by a Franklin Global faculty member:

• Using Franklin Global-approved AI tools to brainstorm ideas, explore a topic, or generate initial drafts, provided the Learner substantially revises the output and genuinely engages with the material;
• Using AI tools to check grammar, spelling, or clarity of writing that the Learner has independently authored;
• Using AI tools to research background information, summarize source material, or generate examples, provided the use is disclosed and the Learner critically evaluates the AI output rather than accepting it uncritically;
• Using AI tools in courses or on assignments where a faculty member has explicitly authorized or assigned AI-assisted work;
• Using approved AI accessibility tools that support Learners with documented learning differences or disabilities; and
• Using AI tools to understand how AI works, including its capabilities, limitations, biases, and societal implications, in support of Franklin Global’s commitment to AI literacy as an educational outcome.

3.3  Prohibited Uses of AI for Learners

The following uses of AI are prohibited for Learners in all circumstances:

• Submitting AI-generated text, code, analysis, images, or any other content as the Learner’s own original work without disclosure, whether in whole or in part;
• Using AI tools during assessments, examinations, or timed exercises unless explicitly authorized by a Franklin Global faculty member in writing before the assessment begins;
• Using AI to generate responses during live dialectic circles, synchronous class sessions, or real-time discussions, and presenting those responses as the Learner’s own thinking;
• Using AI tools to impersonate or speak on behalf of another Learner, faculty member, or any other person;
• Inputting the personally identifiable information of any other Learner, Learning Partner, or Franklin Global faculty or staff member into any AI tool or platform;
• Using AI tools to generate content that is hateful, harassing, sexually explicit, violent, or otherwise contrary to Franklin Global’s community standards; and
• Using unapproved AI tools in any context where a Franklin Global-approved tool has been specifically designated.

3.4  The Dialectic Circle Rule

Franklin Global’s dialectic circles are the heart of its educational model and exist specifically to develop a Learner’s capacity for authentic intellectual discourse, real-time reasoning, and independent thinking. Using AI to generate responses during a dialectic circle fundamentally defeats this purpose.

The following specific rules apply to AI use in dialectic circles and all synchronous live learning sessions:

• Learners must not use any AI tool to generate, draft, or suggest responses during a live session, regardless of whether the session is being assessed;
• Learners must not access AI tools on a second device, browser tab, or application during a live session without explicit authorization from a Franklin Global faculty member;
• Learners who are uncertain about an answer during a live session should say so honestly, as intellectual uncertainty expressed authentically is itself a valuable contribution to dialectic inquiry; and
• Faculty who suspect AI-assisted responses during a live session may ask the Learner to elaborate on or defend their answer in real time.

Why the Dialectic Circle Rule Matters The dialectic circle is where Franklin Global’s educational philosophy is most fully realized. It is not a performance of knowledge, rather it is the development of it. A Learner who reads an AI-generated response in a dialectic circle has not participated; they have recited. Franklin Global’s faculty are trained to recognize and respond to this distinction.

3.5  Disclosure Requirements

Transparency is not optional and is the foundation of academic integrity at Franklin Global. Learners are required to disclose AI use as follows:

• When submitting any work in which an AI tool was used, the Learner must complete an AI Use Disclosure using the standard template in Appendix B, identifying: (a) which tool was used; (b) how it was used; and (c) how the Learner engaged with, revised, or built upon the AI output.
• Disclosure is not an admission of wrongdoing. It is a demonstration of intellectual honesty and is expected regardless of the extent or nature of AI use.
• Faculty may provide course-specific disclosure formats. Where no specific format is provided, a brief written note at the end of the submission using the Appendix B template is sufficient.

Failure to disclose AI use when required constitutes an academic integrity violation under AUP Section 5 and will be addressed in accordance with the consequence framework in Section 9 of this Policy.

3.6  Age-Differentiated Expectations

Franklin Global recognizes that a Grade 6 Learner and a Grade 12 Learner have very different developmental frameworks for understanding AI’s capabilities, limitations, and ethical implications. The following graduated expectations apply:

Grade Band	AI Use Expectations	Learning Partner Oversight
Grades 6–7	Foundational AI literacy focus. Learners are introduced to what AI is, how it works, and its limitations. AI tool use is closely guided by Franklin Global faculty and supervised by Learning Partners. Independent AI use outside of faculty-assigned activities is not expected.	Active supervision expected. Learning Partners should be aware of and monitor any AI tool use in the home learning environment.
Grades 8–9	Guided application. Learners may use approved AI tools for permitted purposes with appropriate disclosure. Emphasis on critical evaluation of AI output and understanding of bias. Franklin Global faculty provide structured AI-assisted assignments.	Regular check-ins expected. Learning Partners should discuss AI use with their Learner and be familiar with course-level AI guidance.
Grades 10–12	Independent and responsible use. Learners are expected to exercise independent judgment about when and how to use AI tools, comply fully with disclosure requirements, and critically evaluate AI output as a matter of course.	Supportive awareness. Learning Partners should be available for questions but Learners are expected to manage their own AI use responsibly.

4. Guidance for Learning Partners

Learning Partners play a distinctive role in Franklin Global’s model. The home is the classroom, and Learning Partners are active participants in the educational environment. This means Learning Partners have both the opportunity and the responsibility to shape how their Learner engages with AI. This section provides practical guidance for Learning Partners on AI in the home learning environment.

4.1  Understanding Your Role

Learning Partners are not expected to be AI experts. They are expected to be informed, engaged, and supportive of Franklin Global’s approach to AI. The most important thing a Learning Partner can do is model honest, thoughtful engagement with technology and reinforce to their Learner that the goal of Franklin Global’s AI standards is not restriction but the development of genuine capability.

The Core Message for Learning Partners Franklin Global does not want Learners to avoid AI; Franklin Global wants them to use it well. A Learning Partner who helps their Learner understand the difference between using AI to think and using AI instead of thinking is doing exactly what Franklin Global’s model calls for.

4.2  How Learning Partners May Support AI Use

Learning Partners may support their Learner’s AI use in the following ways:

• Discussing what AI tools are, how they work, and what their limitations are in age-appropriate terms;
• Reviewing course-level AI guidance with their Learner and helping them understand what is and is not permitted for specific assignments;
• Encouraging their Learner to disclose AI use when required, and modeling honest attribution in their own use of technology;
• Helping their Learner access Franklin Global-approved AI tools and navigate the platforms safely; and
• Alerting Franklin Global faculty or the Head of School if they observe their Learner using AI in a way that appears to violate this Policy or the AUP.

4.3  What Learning Partners Must Not Do

The following conduct by Learning Partners with respect to AI is prohibited:

• Using AI tools to complete, substantially draft, or materially revise a Learner’s submitted academic work. This constitutes facilitation of an academic integrity violation under AUP Section 5.6;
• Using AI tools to generate responses or contributions that a Learner then presents as their own thinking during a dialectic circle or live session;
• Inputting a Learner’s personally identifiable information, including their name, student ID, or academic records, into any AI tool or platform not approved by Franklin Global; and
• Using AI tools to communicate with Franklin Global faculty or staff in a way that misrepresents the Learning Partner’s identity or the nature of their communication.

4.4  Learning Partner Use of AI for Facilitation Purposes

Learning Partners may use AI tools for their own facilitation purposes, for example, to understand course content, research background material, or plan how to support their Learner’s study sessions. This is permitted provided that:

• The Learning Partner does not use AI-generated content as a substitute for the Learner’s own work;
• The Learning Partner does not input student academic records, assessment content, or other confidential Franklin Global information into any AI tool; and
• The Learning Partner uses only Franklin Global-approved AI tools for any activity that involves Franklin Global course materials or student data.

4.5  Notification Rights

Franklin Global is committed to transparency about the AI tools it deploys in its educational programs. Learning Partners have the right to:

• Be informed before Franklin Global introduces a new AI tool into the educational program that their Learner accesses;
• Understand the educational purpose of any AI tool their Learner uses in Franklin Global’s programs;
• Review Franklin Global’s approved AI tools list, which is maintained in the Learner and Learning Partner Handbook; and
• Raise concerns about specific AI tools with the Head of School or designated compliance contact.

Franklin Global’s Learning Partner notification framework is designed to anticipate and align with emerging state-level requirements around AI tool notification, including Florida Senate Bill 482 (the proposed Artificial Intelligence Bill of Rights) and equivalent frameworks in other jurisdictions where Franklin Global serves Learners.

5. Guidance for Faculty and Staff

Franklin Global faculty and staff occupy a unique position in the AI use framework. They are simultaneously subject to this Policy as users of AI tools and responsible for implementing it in their instructional and administrative roles. This section addresses both dimensions.

5.1  Faculty as AI Policy Implementers

Franklin Global faculty members are the primary implementers of Franklin Global’s AI use standards at the course level. This role carries both authority and responsibility:

• Faculty have the authority to set course-specific AI policies that are more or less permissive than this Policy’s baseline, within the limits set by AUP Section 4.3 (Prohibited Uses);
• Faculty must communicate course-level AI expectations clearly and in writing in the course syllabus or assignment instructions before any assignment is due;
• Faculty must document course-level AI guidance in Franklin Global’s designated curriculum system for administrative review; and
• Faculty who change their course-level AI policy mid-term must provide Learners with reasonable advance notice.

Faculty AI Policy Authority Franklin Global faculty may make AI use more permissive than this Policy’s baseline, for example, by authorizing AI-assisted drafting on a specific assignment. Faculty may also make AI use more restrictive, for example, by designating an assignment as entirely AI-free. What faculty may not do is permit uses that are prohibited under AUP Section 4.3 or elsewhere in this Policy, regardless of educational rationale.

5.2  Instructional Use of AI by Faculty

Franklin Global faculty members may use AI tools to support their instructional practice in the following ways:

• Designing and developing course materials, lesson plans, and assessment frameworks;
• Generating examples, analogies, or discussion prompts to support Learner engagement;
• Providing feedback on Learner work, provided that the feedback reflects the faculty member’s own professional judgment and is not presented as human-generated when it was AI-assisted;
• Using AI tools to research pedagogical approaches, subject matter content, or professional development material; and
• Demonstrating AI tool use to Learners as part of AI literacy instruction.

Franklin Global faculty who use AI tools in their instructional practice should be transparent with Learners about that use. Modeling the same transparency they expect of Learners is both professionally appropriate and pedagogically valuable.

5.3  Handling Suspected AI Violations

When a Franklin Global faculty member suspects that a Learner has used AI in an unauthorized manner, the following process applies:

• The faculty member should first have a direct, good-faith conversation with the Learner to understand the context before escalating;
• If the faculty member believes a violation has occurred after that conversation, they should document the concern and report it to the Head of School in accordance with AUP Section 5.8;
• Faculty should not use AI detection tools as the sole basis for an academic integrity finding, as such tools produce false positives at rates that make them unreliable as standalone evidence; and
• Faculty may ask Learners to explain, defend, or expand on submitted work verbally as part of assessing authorship.

Important: AI Detection Tools Are Not Reliable Evidence AI content detection tools have documented false positive rates that disproportionately affect non-native English speakers, neurodiverse writers, and students from certain cultural backgrounds. Franklin Global prohibits using AI detection tool output as the sole or primary basis for an academic integrity finding. Detection tool output may be one factor in a broader assessment, but it must be combined with other evidence and a direct conversation with the Learner.

5.4  Professional Use of AI by Staff

Franklin Global staff members may use AI tools to support their administrative and operational functions, subject to the requirements in Section 6 of this Policy. Permitted professional uses include:

• Drafting communications, reports, and documentation, provided the staff member reviews, revises, and takes responsibility for the final output;
• Using AI tools for research, data analysis, or operational planning;
• Using AI tools to support professional development and learning; and
• Any other administrative use that does not involve inputting confidential student data into an unapproved AI tool.

Franklin Global staff members must not use AI tools that have not been approved by Franklin Global for any task that involves student personally identifiable information, student academic records, or confidential Franklin Global operational data.

5.5  Mandatory AI Literacy

Franklin Global faculty and staff are expected to maintain a functional understanding of AI tools relevant to their role. This includes:

• Understanding the AI tools Franklin Global has approved for educational use and how they function;
• Understanding the basics of how generative AI produces output, including its limitations, potential biases, and tendency to generate plausible-sounding but inaccurate information; and
• Completing any AI literacy training or professional development designated by Franklin Global as mandatory.

6. Administrative Use of Artificial Intelligence

Administrative AI use is one of the most consequential and least governed dimensions of AI in K-12 education. Franklin Global is committed to using AI tools to improve its operations, reduce administrative burden, and serve its community more effectively, while ensuring that those uses never compromise student privacy, data security, or the integrity of Franklin Global’s decision-making.

6.1  Permitted Administrative Uses 

Franklin Global may use AI tools for the following administrative purposes, subject to the requirements of this section:

• Drafting and editing internal and external communications, policies, reports, and documentation;
• Analyzing operational data, enrollment trends, and program performance metrics, using only de-identified or aggregated data in any AI tool not covered by an appropriate data processing agreement;
• Supporting accreditation, compliance, and quality assurance processes;
• Automating routine administrative tasks such as scheduling, formatting, and document organization;
• Researching and benchmarking educational practices, policies, and operational approaches; and
• Supporting professional development, training design, and faculty support functions.

6.2  Prohibited Administrative Uses

The following administrative uses of AI are prohibited:

• Inputting student personally identifiable information, including names, student IDs, academic records, assessment results, IEP or 504 documentation, or contact information, into any AI tool that has not been approved by Franklin Global and covered by an appropriate data processing agreement;
• Using AI tools to make or materially influence high-stakes decisions about individual Learners, including admissions, academic standing, discipline, or learning support determinations, without human review and final human decision-making authority;
• Using AI tools to generate communications that are sent to Learners and their Learning Partners without human review and approval;
• Using unapproved AI tools for any task that involves Franklin Global’s confidential operational data, financial records, or personnel information; and
• Using AI tools in any manner that would violate Franklin Global’s Privacy Policy, the AUP, or applicable law including FERPA, COPPA, and GDPR.

6.3  The Human-in-the-Loop Requirement

For any administrative decision that materially affects a Learner, Learning Partner, or Franklin Global faculty or staff member, AI tools may support the decision-making process but may not replace human judgment. The human-in-the-loop requirement means:

• AI output used in an administrative context must be reviewed by a qualified Franklin Global staff member before being relied upon or acted on;
• The staff member responsible for a decision is accountable for that decision regardless of whether AI tools were used to inform it; and
• Franklin Global will not implement automated decision-making systems that make consequential determinations about individuals without human oversight.

IMPORTANT: Human Decision-Making Authority Franklin Global’s use of AI in administrative functions is designed to support, not replace, the judgment of qualified educators and administrators. Any decision that affects a Learner’s academic standing, enrollment status, disciplinary record, or learning support plan must be made by a human being with appropriate authority, even when AI tools were used to inform the analysis underlying that decision.

6.4  Shadow Use Prevention

Franklin Global is aware that administrative staff may use personal AI tools, including consumer chatbots and AI writing assistants, for work-related tasks outside of Franklin Global’s approved systems. This “Shadow Use” creates significant legal and privacy risks, particularly when it involves student data.

Franklin Global staff are required to:

• Use only Franklin Global-approved AI tools for any task that involves student information, Franklin Global operational data, or confidential communications;
• Report any uncertainty about whether a specific AI tool is approved for a specific use to the Head of School or designated technology contact before using it; and
• Never use a personal AI account or consumer AI subscription to process Franklin Global student data, even on a one-time or incidental basis.

7. AI Tool Vetting and Approval

Franklin Global maintains a formal AI tool vetting process to ensure that all AI tools used in its educational programs and administrative operations meet Franklin Global’s standards for privacy compliance, data security, age-appropriateness, and alignment with Franklin Global’s educational philosophy. No AI tool may be used with Learners or with student data unless it has been approved through this process.

7.1  Vetting Criteria

All AI tools submitted for approval are evaluated against the following criteria:

• Data privacy compliance: Does the tool comply with FERPA, COPPA, and GDPR/UK GDPR to the extent applicable? Does the vendor enter into a Data Processing Agreement (DPA) with Franklin Global?
• Age-appropriateness: Is the tool appropriate for use by Learners in Grades 6–12? Does the vendor comply with COPPA’s requirements for tools accessed by Learners under 13?
• Data retention and security: What data does the tool collect? How is it stored, protected, and deleted? What is the vendor’s data breach response protocol?
• Alignment with educational philosophy: Does the tool support genuine learning, critical thinking, and intellectual development? Does it risk undermining the educational outcomes Franklin Global is trying to achieve?
• Bias and accuracy: Is the tool’s output reasonably accurate and free from documented biases that could harm Learners or produce misleading educational content?
• Terms of service: Are the vendor’s terms of service compatible with Franklin Global’s obligations to its community, including its privacy commitments and accreditation obligations?
• Prohibition on model training: Does the vendor contractually commit to not using student data or PII to train, improve, or refine its AI models?

7.2  Approval Process

The AI tool vetting process is administered by the Head of School in consultation with Franklin Global’s technology team. The process is as follows:

• Any Franklin Global faculty member, Learning Partner, or Learner who wishes to propose an AI tool for approval may submit a request through Franklin Global’s designated inquiry process;
• The Head of School or designee will evaluate the tool against the criteria in Section 7.1 and may request additional information from the vendor;
• Tools that meet all criteria will be added to the Franklin Global Approved AI Tools List in Appendix A and communicated to the community through the Learner and Learning Partner Handbook; and
• Tools that do not meet all criteria will not be approved, and the requesting party will be informed of the reasons.

Franklin Global reserves the right to remove a previously approved tool from the Approved AI Tools List at any time if new information about its data practices, safety record, or educational impact warrants removal. Affected community members will be notified promptly.

7.3  Learning Partner Notification

Franklin Global is committed to transparency with Learning Partners about the AI tools used in its educational programs. Prior to introducing a new AI tool into Franklin Global’s programs, Franklin Global will:

• Notify Learning Partners of the tool’s name and the educational purpose it serves;
• Provide a general description of how the tool supports learning in Franklin Global’s programs;
• Summarize what data the tool collects and the safeguards in place to protect it; and
• Provide a point of contact for Learning Partners who have questions or concerns about specific AI tools.

This notification framework is designed to reflect Franklin Global’s commitment to transparency and to align with applicable state-level AI notification requirements where they apply.

8. Privacy, Data, and Security

The intersection of AI tools and student data is the highest-risk area in Franklin Global’s AI governance framework. This section establishes the specific data protection requirements that govern all AI tool use at Franklin Global, and should be read alongside Franklin Global’s Privacy Policy, which is incorporated by reference.

8.1  The Student Data Protection Rule

The most important data protection rule in this Policy is simple: no student personally identifiable information (PII) may be input into any AI tool that is not covered by a Franklin Global Data Processing Agreement (DPA).

The Student Data Protection Rule Student data and PII, including names, student IDs, email addresses, academic records, assessment results, learning support documentation, and any other information that could identify a student, may ONLY be processed through AI tools that: (1) are on Franklin Global’s Approved AI Tools List, AND (2) are covered by a Franklin Global Data Processing Agreement with the vendor. Consumer AI tools, including personal accounts on approved platforms, do not satisfy either condition. Franklin Global further prohibits the use of any AI tool that uses student data or PII to train, improve, or refine its models.

8.2  Applicable Legal Frameworks

Franklin Global’s AI data practices are designed to comply with the following legal frameworks to the extent applicable:

• FERPA: Student education records maintained by Franklin Global are protected under FERPA. AI tools used to process student education records must comply with FERPA’s requirements, including the school officials exception, where applicable.
• COPPA: AI tools accessed by Learners under the age of 13 must comply with COPPA’s requirements for online services directed at children, including parental consent requirements. Franklin Global’s AI tool vetting process evaluates COPPA compliance for all tools accessible to middle school Learners.
• GDPR and UK GDPR: For Learners located in the European Union or United Kingdom, AI tool use must comply with GDPR and UK GDPR data processing requirements, including lawful basis, data minimization, and transfer restrictions.
• State-level and international student privacy laws: Many U.S. states have enacted student privacy laws that apply to AI tools, and equivalent frameworks exist in other countries where Franklin Global serves Learners. Franklin Global’s vetting process evaluates compliance with applicable U.S. state laws and international privacy frameworks, and Franklin Global will endeavor to comply with applicable student privacy requirements regardless of the number of Learners served in a given state or country.

8.3  Data Processing Agreements

Franklin Global requires Data Processing Agreements (DPAs) with all third-party AI tool vendors that process student personal information on Franklin Global’s behalf. DPAs must address:

• The specific categories of student data the vendor may process;
• The purposes for which that data may be used, which must be limited to providing the educational service;
• Data retention periods and deletion obligations upon contract termination;
• Security standards and breach notification requirements; and
• Subprocessor restrictions and requirements.

8.4  Learner Data Minimization

Franklin Global and its faculty and staff practice data minimization in all AI-related contexts:

• Faculty and staff should not input more student information into an AI tool than is strictly necessary to accomplish the educational or administrative purpose at hand;
• Learners should not share more personal information about themselves or others in AI platforms than is necessary for the task they are completing; and
• Franklin Global’s AI tool vetting process evaluates whether a tool’s data collection practices are proportionate to its educational purpose.

8.5  AI-Generated Content and Accuracy

All users of AI tools at Franklin Global, including Learners, Learning Partners, faculty, staff, and administrators, are responsible for verifying the accuracy of AI-generated content before relying on it or submitting it. AI tools can and do generate plausible-sounding but factually incorrect, biased, or misleading content. Franklin Global’s AI literacy commitment includes ensuring that all community members understand this limitation and apply critical evaluation to AI output as a matter of course.

9. Consequences and Enforcement

Violations of this Policy are addressed through the same consequence framework established in Section 9 of Franklin Global’s Acceptable Use Policy (AUP). This section provides AI-specific guidance within that framework and should be read alongside AUP Section 9.

9.1  AI Violations Within the AUP Framework

AI-related violations fall within the three-track framework established in AUP Section 9.1:

• Track 1 (Technology Misuse and Platform Conduct): covers unauthorized AI tool use, use of unapproved tools, and AI-related privacy violations such as inputting another person’s PII into an AI platform;
• Track 2 (Community Conduct): covers AI-generated content that violates Franklin Global’s community standards, including hateful, harassing, or sexually explicit AI-generated material; and
• Track 3 (Academic Integrity): covers unauthorized AI use in academic work, failure to disclose AI use, and AI-assisted academic dishonesty.

9.2  The Educational First Response

Franklin Global recognizes that AI literacy is still developing across all age groups among Learners, Learning Partners, faculty, and administrators alike. For a first violation that appears to stem from genuine misunderstanding rather than intent to deceive or circumvent, Franklin Global’s primary response will be educational rather than punitive. This includes:

• A direct conversation with the Learner and Learning Partner about what the violation was and why it matters;
• A review of the specific Policy provisions that apply and how they should be applied in similar situations in the future;
• An opportunity to redo or resubmit affected work in appropriate circumstances; and
• Documentation of the educational intervention in the Learner’s internal conduct record.

The educational first response does not apply to intentional violations, repeated violations, or violations that fall within Tier 3 or Tier 4 of the AUP’s consequence framework. For those violations, the full consequence framework applies.

9.3  Specific Consequences for AI Violations

The following consequence guidance applies specifically to AI-related violations, within the tiered framework of AUP Section 9.2:

• Tier 1 (Learning and Clarification): First violation stemming from a misunderstanding of AI use expectations: educational conversation with an educator or tutor, review of Franklin Global’s AI Use Guidelines, reflection on the learning process, and opportunity to revise or resubmit affected work. 
• Tier 2 (Accountability and Revision): AI use that does not align with course expectations or repeats a previous concern: meeting with the Learner to review the work and learning process, required revision, alternative assessment, or resubmission, family notification when appropriate, and completion of an AI literacy or academic integrity learning activity. 
• Tier 3 (Formal Academic Integrity Review): Concerns suggesting significant, intentional, or repeated misuse of AI: formal review by school leadership, family conference with the Learner, alternative demonstration of learning required, academic consequences that may include loss of credit on the affected assessment, and an individualized support plan to rebuild responsible academic practices. 
• Tier 4 (Safety, Harm, or Illegal Use): AI use that exploits, harms, threatens, or endangers others falls outside the scope of academic misconduct and will be addressed as a serious safety matter: immediate administrative review, temporary removal from Franklin Global activities pending investigation, family notification, and additional actions, including withdrawal from the program or referral to appropriate authorities when required. 

9.4  Faculty and Staff Violations

Franklin Global faculty and staff who violate this Policy, including through Shadow Use of AI tools involving student data, failure to maintain course-level AI guidance, or use of AI detection tools as sole evidence of academic integrity violations, will be addressed in accordance with Franklin Global’s applicable employment policies and may face disciplinary action up to and including termination.

9.5  Reporting Concerns

Any member of the Franklin Global community may report a suspected AI use policy violation to the Head of School or designated compliance contact. Franklin Global will not tolerate retaliation against any person who makes a good-faith report of a suspected violation.

10. Policy Review and Updates

Franklin Global commits to reviewing this Policy no less than semi-annually and at the start of each semester, given the pace of change in artificial intelligence technology, applicable law, and educational best practices.

Franklin Global reserves the right to update or modify this Policy at any time. Where changes are material (meaning they affect the rights or obligations of Learners, Learning Partners, or Franklin Global faculty and staff), Franklin Global will provide reasonable advance notice through its designated communication channels.

Continued access to Franklin Global’s platforms and programs following notice of a Policy update constitutes acceptance of the updated terms. All Learners and Learning Partners will be required to re-acknowledge this Policy at the start of each academic year, regardless of whether material changes have been made since the prior acknowledgment.

Questions about this Policy or its application should be directed to the Head of School or the designated compliance contact.

The current version of this Policy, including its last updated date, is available at https://franklinglobal.org/artificial-intelligence-use-policy/.

Appendix A – Franklin Global-Approved AI Tools List

This is a living document. The Franklin Global-approved AI tools list is reviewed and updated as part of Franklin Global’s ongoing AI tool vetting process described in Section 7. Tools are added or removed as their compliance status, educational alignment, and data practices are evaluated.

IMPORTANT: This list is current as of the Last Updated date shown on the cover page of this Policy. The most current version of this list is maintained in the Franklin Global Learner and Learning Partner Handbook. Faculty will also communicate approved tools in course syllabi. When in doubt about whether a tool is approved, contact the Head of School or designated technology contact before use.

Tool Name	Vendor	Approved Use(s)	Grade Levels	DPA Status
Desmos	Desmos Studio	Calculator and graphing for math and science	6–12	Executed
Gizmos	Explore Learning	Interactive simulations and labs for math and science	6–12	Executed
Follett Destiny	Follett	Library resources and research	6–12	Executed

Additional rows to be completed as tools are vetted and approved. Contact the Head of School to propose a tool for evaluation.

Appendix B – AI Use Disclosure Template

Learners are required to complete this disclosure whenever an AI tool is used in connection with submitted academic work. This template may be completed digitally and appended to the end of a submission, or Franklin Global faculty may provide a course-specific format. If faculty provide a specific format, use that format instead.

Why Franklin Global Requires AI Use Disclosure Disclosing AI use is not an admission of wrongdoing. It is a demonstration of intellectual honesty and transparency. Franklin Global requires disclosure because honest attribution of AI tools as much as human sources is part of what it means to be an ethical scholar and a trustworthy member of the Franklin Global community.

AI USE DISCLOSURE

Learner Name:

Assignment / Course:

Submission Date:

AI Tool(s) Used: (list each tool by name)

How the tool was used: (describe the specific task(s) for which AI was used: e.g., brainstorming, grammar checking, research, code suggestions)

How I engaged with the output: (describe how you revised, built upon, evaluated, or departed from the AI’s output: this is the most important part of the disclosure)

Portions of the submission that are AI-assisted: (identify specific sections or elements if applicable, or state “none: AI was used only for process support”)

By submitting this disclosure, I confirm that the information above is accurate and complete, and that the submitted work represents my own genuine understanding and intellectual effort except as described above.