7540.09 - ARTIFICIAL INTELLIGENCE ("AI")

The Board of Education acknowledges the positive impact and transformative potential of Artificial Intelligence ("AI") in education and operations, emphasizing a balanced, people-centered approach. It supports the responsible and innovative use of AI in classrooms and professional settings, with the understanding that AI should enhance human interaction and instruction, not replace it, and all AI-driven decisions require human review.

Through this policy, the Board aims to prepare students for success, encourage innovation for classroom instruction, and embrace opportunities for operational efficiency, while providing for consistent expectations, standards, and approval processes for safe and responsible implementation and integration of AI.

The Superintendent is authorized to support the use of artificial intelligence technology when its use is consistent with the District’s mission, goals, and operational integrity. The Technology Supervisor is responsible for overseeing and ensuring compliance of this policy. 

Definitions

Artificial Intelligence ("AI"): A machine-based system that can, for a given set of human-defined objectives, make predictions, recommendations, or decisions influencing real or virtual environments. Artificial intelligence systems use machine and human based inputs to perceive real and virtual environments; abstract such perceptions into models through analysis in an automated manner; and use model inference to formulate options for information or action. See 15 U.S.C. 9401, Sec. 3. 

Generative AI: Any internet-based generative artificial intelligence program that makes use of large language model algorithms to make something new. AI used for auto-complete, minor text predictions, and/or grammar/spelling/punctuation suggestions, commonly found in most word-processing applications, is not considered generative AI. See A.C. 3342-3-01.8(B)(15). 

AI tool: A software application that uses artificial intelligence technologies, like machine learning and natural language processing ("NLP"), to perform tasks that typically require human intelligence, such as understanding language, analyzing data, solving problems, and creating content, often by learning from patterns in large datasets to improve over time.”

Natural Language Processing ("NLP"): A field of artificial intelligence that focuses on enabling computers to understand, interpret, and respond to human language in a meaningful way. Examples of NLP include, but are not limited to, Grammarly, GPT-Based APIs, Google Cloud Natural Language AI, Microsoft Azure Text Analytics, IBM Watson NLP, Amazon Comprehend, etc.

Large Language Model ("LLM"): A sophisticated AI system trained on extensive text data to process and produce language; recognize patterns, grammar, and nuances. It can perform tasks like text generation, question answering, and language translation.

Algorithm: A set of rules or instructions guiding AI operations and decision-making.

Personally Identifiable Data/Personal Data: Refers to any information that can directly or indirectly identify an individual including, but not limited to, names, addresses, student records, and health information.

Proprietary Information/Data: Refers to a broad category of non-public, sensitive, or confidential data belonging to the District, its staff, or its operations. This information is considered the District's. This information is generally protected from unauthorized disclosure or use.

Open AI ("Open-Source AI"): AI models where the developers openly share the model's architecture, underlying code, and often the "weights" (the learned parameters of the model), and sometimes the training data. Open AI models accessed publicly present a high risk of data release, as data input is often used for AI tool training and can be publicly available. Open AI models may require the District to implement and manage its own wrapper or filtering layer. As a result, it is not recommended that Open AI tools/applications are used in districts due to the high potential of violating Federal and State laws. Open-Source AI also produces less reliable content because it is accessing a pool of data that is not universally verified as accurate.

Closed AI ("Closed-Source/Proprietary AI"): AI models where the developers obscure or protect the model's architecture, underlying code, training data, and weights. Users interact with the model via a restricted service. Closed AI may offer better, contractually-guaranteed data security (e.g., "enterprise" versions), but its "black box" nature still requires a formal audit and contract. Closed AI developers typically manage these filters internally. Closed-Source or Proprietary AI produces more reliable results because it is accessing data sources that are controlled and can be verified as accurate.

AI LITERACY

The Board recognizes the importance of preparing students and educators for the successful integration of innovative technologies. To that end, the Board directs the administration to responsibly integrate AI by building AI literacy for all students and educators, including integration of AI into relevant curriculum, professional learning opportunities, and safe and responsible usage. 

STAKEHOLDER ENGAGEMENT

The Superintendent shall establish an AI workgroup to inform AI policy and implementation. The workgroup should include educators who are representative of grade levels and departments, including special education and related services professionals, other relevant staff, Board members, and students, as well as external representatives such as local businesses and postsecondary institutions. Educators and staff should be given the opportunity to explore and gain experience with applications and integrated approaches to achieving the District’s mission and priorities. The workgroup should regularly review new research and guidance and provide ongoing feedback to the Board.

Parents and community members should be informed through ongoing engagement about the skills students need for the future workforce and how AI is being used in the classroom. Educational resources may be provided to empower families to understand the potential risks associated with the unsupervised use of AI tools. Regular AI updates, including the use of tools and opportunities for feedback, shall be integrated into the existing family and community engagement strategy. 

DATA PRIVACY AND SECURITY

The District is committed to protecting the privacy and security of all student and staff data. The adoption and implementation of any AI tool must adhere to existing data privacy and security policies that include, but are not limited to, Personally Identifiable Information ("PII"), FERPA, and any other relevant state of Ohio and Federal laws. See Policy 8330 – Student Records; Policy 8350 - Confidentiality; and Policy 8351 - Security Breach of Confidential Databases. AI tools should only access, store, or process data that is necessary, and must do so in a secure, transparent, and ethical manner. AI systems must be vetted to ensure they meet rigorous standards for data encryption, access control, and responsible data use.
 
Users must also follow the terms of service, including appropriate age limits.  

PROCUREMENT AND EVALUATION OF AI TOOLS

The adoption of AI-enabled tools should be conducted in accordance with existing procurement policies and in alignment with the District’s core values, goals, and priorities. Selection procedures must ensure that any AI tool adheres to data privacy and security policies. Evaluation of tools must also address alignment to instructional and operational goals, accessibility, and cost. All third-party vendors providing AI tools must comply with District standards and State and Federal law for data protection, ethical use, and accessibility. 

The District approves the use of Closed AI tools only, that have been carefully reviewed, evaluated, and approved by Curriculum/Technology Committee for students and staff use.

ETHICAL USE OF AI

The Superintendent is charged with verifying that the design and implementation of AI is done in a safe and responsible manner that keeps people at the core of every AI-related decision. AI implementation should be human-centered and should empower students, educators, and communities. It is a tool to support learning and teaching, not a substitute for student effort or the role of the educator. Accordingly, users should critically analyze AI output, respect safeguards and rules, and be transparent about its use.  

District employees who use AI technologies must do so in ways consistent with institutional values, privacy standards, Family Educational Rights and Privacy Act ("FERPA"), Individuals with Disabilities Education Improvement Act ("IDEA"), copyright laws, and ethical principles, honesty, trustworthiness, and personal dignity of both employees and students. 

ACCEPTABLE USE

The District recognizes that responsible and appropriate uses of AI by students and educators will vary depending on the context including, but not limited to, grade level, subject, and/or the nature of the classroom activity or assignment.

Expectations for acceptable student uses should be clearly articulated by educators in alignment with policy and guided by the specific requirements for an assignment or activity. This includes specifying AI use expectations in course syllabi and assignment instructions when relevant. These expectations should clearly articulate the expectations of use, types of relevant assignments where AI use is acceptable, and the required format for references. 

As noted above, students may use AI tools for academic purposes when specifically and clearly permitted by their teacher(s). The use of AI must be properly disclosed and cited in accordance with the established guidelines and not be employed to undermine authentic learning or learning objectives for the course or assignment. 

If a student has any questions about whether they are permitted to use AI tools for a specific class assignment, they should ask their teacher(s). 

Educators should consider the impact on learning objectives and assessment of student learning when designing related instruction and classroom activities. No assignment shall require the use of a tool that is not provided by the District. AI tools approved for use should be clearly communicated.

Employees may integrate AI tools into their instruction at their discretion and should clearly define the parameters for AI usage in the classroom by students using District-approved AI applications/tools. 

Employees shall not input sensitive, confidential, personally identifiable, or proprietary information about students, colleagues, or institutional operations into AI systems that lack safeguards and policies to protect such data from being used in their training models, and if such information will be entered into an AI system, employees shall seek the approval of their supervisor or Principal before doing so.

Expectations for educators, staff, and third-party use should align with District priorities. Educator use should be in alignment with the Licensure Code of Conduct for Ohio’s Educators. Educators and staff must model appropriate acceptable use practices when using AI tools for instructional and operational uses. 

Use of tools that have not been approved is not permitted. 

All users are expected to employ AI tools solely for educational and related operational purposes, upholding values of respect and academic integrity, and in alignment with other related Board policies. Using AI tools for bullying, harassment, and any form of intimidation is strictly prohibited and should be addressed in alignment with existing behavior and discipline policies. See Policy 2240 – Controversial Issues; Policy 2266 – Nondiscrimination on the Basis of Sex in Education Programs and Activities; Policy 5136 – Personal Communication Devices; Policy 5500 – Student Conduct; Policy 5517 – Anti-Harassment; Policy 5517.01 – Bullying; Policy 7540.03 – Student Technology Acceptable Use and Safety; Policy 7540.04 – Staff Technology Acceptable Use and Safety. 

Students and staff with concerns regarding inappropriate use that violates Board policies and/or applicable state or federal laws should contact the appropriate building administrators. 

ACADEMIC INTEGRITY

The Board recognizes that the responsible use of AI requires the highest standards of academic integrity with clear expectations for students, educators, and staff regarding the ethical use of AI tools. AI-enabled tools may be used to support student work (such as brainstorming or feedback), but AI-generated work must not replace student work. Students are expected to complete assignments and assessments in a manner that reflects their own understanding and effort, critically analyze AI-generated content and not misrepresent it as original work, and use proper citations and references for AI-assisted work according to existing policies and expectations relevant to assignments (such as APA or MLA style formats). 

The Superintendent shall specify procedures for investigating and addressing suspected misuse in alignment with existing academic integrity policies. 

ACADEMIC ACCESSIBILITY

AI tools can be utilized to assist students with disabilities in accessing and understanding written materials. For example, text-to-speech software can help students with specific learning disabilities, visual impairments, or other disabilities in reading texts, and AI-powered translation tools can help students with hearing impairments understand spoken language (e.g., create transcripts or provide closed-captioning for spoken material). Specific use of AI technologies beyond universal application for students with disabilities is best addressed in each student's Individual Education Plan ("IEP"). 

IMPLEMENTATION AND REVIEW

The Board will monitor developments in AI technology and update policies to address emerging risks. This policy should be reviewed often for effectiveness; alignment to district, school, educator, and student needs; considerations of ongoing innovation; related data privacy and management policies; and impact on students, including learning outcomes.  

OTHER CONSIDERATIONS

NON-ACADEMIC USE OF AI

Students and staff are prohibited from using AI to generate false or knowingly misleading representations of other students, staff, volunteers, or Board members that are reasonably interpreted as derogatory, threatening, or otherwise objectionable to a reasonable person, including by way of AI generated or manipulated visual or verbal depictions of any such individual, or the distribution of such depictions through any means, for example via social media, regardless of whether the distributor created the depictions themselves. This provision expressly prohibits the creation and/or distribution of Non-Consensual Intimate Imagery ("NCII"). This paragraph shall be implemented in a manner consistent with individuals’ First Amendment rights. 

ENFORCEMENT

Violation of this policy may result in disciplinary consequences. Students may be disciplined for violations, up to and including suspension or expulsion. Staff may be disciplined for violations, up to and including suspension or termination of employment. The Administration will refer any illegal acts to law enforcement. 

NON-CONSENSUAL INTIMATE IMAGERY

National digital safety experts have emphasized the importance of addressing issues related to Non-Consensual Intimate Imagery ("NCII"), particularly in terms of local policies on digital wellness and cyberbullying. The Center for Democracy & Technology has created a model policy and related resources that districts and schools may want to consider incorporating into relevant local policies. In potential cases where NCII may be used for the purposes of sexual extortion, schools and districts should be aware of Braden’s Law and consider how it may apply within existing local policies, as the law classifies sexual extortion as a felony offense in Ohio.

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