AI and Automated Decision Making Notice

AI and Automated Decision Making Notice

This Notice explains how Substantial Group Limited and its subsidiaries listed in our Privacy Policy use artificial intelligence (“AI”) and other automated technologies when providing and managing our services.

It supplements our Privacy Policy, which explains more generally how we collect and use your personal data, the legal bases on which we process it and your data protection rights.

How we use AI

We use AI and automated technologies to help us provide, manage and improve our services. These technologies may be used to:

• provide customer support and respond to customer enquiries;
• assist with and carry out actions relating to customer accounts;
• analyse information relating to our customers and services;
• identify issues, risks or unusual activity;
• make predictions, recommendations, classifications or other assessments; and
• make or support decisions relating to our customers and services.

The ways in which we use AI will develop over time. We will update this Notice where we introduce material new uses of AI involving personal data.

What personal data do we use?

Depending on the particular use of AI, we may process information including your Identity Data, Contact Data, Transaction Data, Usage Data, Technical Data, Profile Data and information contained in your communications with us.

Further information about these categories of personal data and how we collect them is available in our Privacy Policy.

AI systems may also generate information about you from the information available to them, such as recommendations, classifications, predictions or other assessments.

How do we use AI to make decisions?

Some of our AI systems may make or support decisions or take actions relating to you. The table below provides further information about the material ways in which we currently use these technologies.

Use of AI

What information may be used?

What does the AI do?

What could this mean for you?

Human involvement / safeguards

Customer service and account management

Identity, Contact and Profile Data, account records and information contained in your communications with us

Checks identity, responds to enquiries, updates contact details, adds account contacts and records and routes, closes or combines support cases

Your enquiry or account changes may be carried out, automatically

You may request that your enquiry or an appropriate decision is referred to a member of our customer support team

Billing and payments

Identity, Contact and Transaction Data, bank details and relevant communications

Provides invoices and payment links, sets up Direct Debits, changes billing dates, arranges instalments, assesses payment extensions and applies outage credits

Your bills, payment arrangements or service cut-off date may change automatically

Eligibility rules and automated checks apply. You may request human review

Contract Buy Out claims

Identity, Contact and Transaction Data, your previous provider’s final bill and claim details

Submits claims and bills for automated checking and tracks progress

Eligible claims may be approved and paid automatically

Claims over £300 require human approval. Other claims are subject to automated checks and payment conditions

Technical support, visits and equipment

Contact, Usage and Technical Data, equipment records, communications and photos, and recorded care needs

Checks faults, restarts equipment, books or changes installations, books, changes or cancels fault visits, and arranges equipment deliveries or returns

Your connection may briefly restart, appointments may change or equipment may be sent or returned

Automated checks apply to account changes. Cases can be referred to our support team

Orders, contracts and add-ons

Identity, Contact, Transaction and Profile Data, service availability and relevant communications

Quotes prices, places orders, renews or changes packages and adds or removes extras

Your services, charges or contract term may change; removing a phone service may permanently lose its number

Customer acceptance is required for these changes and is assessed by AI. You may request human review

Service monitoring and improvement

Customer communications, support case records and associated account information

Summarises cases, assesses service quality and tests changes using previous cases

Your previous interactions may be analysed to improve customer support

Testing does not change your account or send messages to you

Automated decisions which significantly affect you

We may use automated technologies to make decisions without meaningful human involvement.

Where applicable, we will put appropriate safeguards in place, including providing you with information about the decision and enabling you to make representations about the decision and obtain human intervention.

These may include giving you the opportunity to:

• ask us to review the decision;
• obtain human intervention;
• provide additional information or express your point of view; and
• challenge the decision.

Details of any significant automated decisions we currently make are identified in the table above.

Your rights

You have rights in relation to your personal data, including rights of access, correction, erasure, restriction and objection in certain circumstances which are described in the Your Legal Rights section of our Privacy Policy.

Where we make a decision about you based solely on automated processing which produces a legal or similarly significant effect on you, you also have additional rights and safeguards. These include the right to:

• receive information about the decision;
• make representations to us about the decision; and
• obtain human intervention in relation to the decision.

You can contact us if you believe an automated decision is incorrect or would like us to reconsider it. We will consider any information you provide as part of that review.

Contact us

If you have any questions about our use of AI or automated decision-making, or wish to ask for human review of an automated decision, please contact us using the details in our Privacy Policy.

Last updated 27 October 2026