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AI Transparency

How Social Home uses artificial intelligence — and your rights under EU law

Last updated: 2 July 2025

Social Home uses artificial intelligence in several parts of our platform — from AI-powered chatbots that respond to guest messages, to document generation tools that help property managers draft tenancy agreements. We believe you have a right to know when you are interacting with AI and how it is used in decisions that may affect you.

This page is published in compliance with the EU AI Act (Regulation 2024/1689), the world's first comprehensive legal framework for artificial intelligence. It gives you a complete inventory of our AI systems, explains the level of human oversight applied to each, and tells you how to exercise your rights.

10 Limited-Risk AI systems (Art. 50 — disclosure required)
9 High-Risk AI systems (Annex III — full compliance by Aug 2027)
3 Minimal-Risk AI systems
Limited Risk

Chatbots & AI-Generated Content

EU AI Act Article 50 — These systems interact directly with people or produce content that may appear human-generated. We are required to disclose that you are interacting with AI, and to label AI-generated content appropriately. Compliance deadline: 2 August 2026.

What this means for you: When you interact with any of these systems — by SMS, email, phone, or WhatsApp — you are communicating with an AI. You always have the right to request a human staff member.

SMS AI Concierge

Guest & Tenant Communication

Limited Risk

AI-drafted replies to guest and tenant SMS messages. Handles booking questions, check-in instructions, maintenance requests, and general enquiries. Users interact directly with this AI system via text message.

Data Processed
phone numbersmessage contentbooking detailsproperty context
Autonomy Level

Autonomous with Review

Human Oversight

Property managers can view all AI conversations in the Unified Inbox. Escalation rules route complex cases to human review. Managers can override any response.

AI Providers

Groq (Llama), Google Gemini, DeepSeek, OpenRouter

EU AI Act

Art. 50(1), Art. 50(2)

Voice AI Agent (Retell)

Guest & Tenant Communication

Limited Risk

AI voice assistant handling inbound and outbound telephone calls. Answers property enquiries, provides booking information, routes callers to human departments, and conducts automated outreach. Callers interact directly with this AI system.

Data Processed
voice recordingscall transcriptsphone numbersbooking data
Autonomy Level

Autonomous with Review

Human Oversight

All calls are recorded and transcribed. Callers can request transfer to a human agent at any time. Call logs are reviewed by property managers. Business-hours rules enforced.

AI Providers

Retell AI, Groq (Whisper), OpenRouter

EU AI Act

Art. 50(1), Art. 50(2), Art. 50(4)

Email AI Concierge

Guest & Tenant Communication

Limited Risk

AI system that reads and responds to inbound emails from guests and tenants via OTA relay addresses and direct email. Parses booking-related content and drafts replies.

Data Processed
email contentsender addressesbooking referencesproperty details
Autonomy Level

Autonomous with Review

Human Oversight

All AI email responses are logged in the Unified Inbox. Property managers can review and override responses. Escalation triggers flag complex or sensitive emails for human review.

AI Providers

Groq (Llama), Google Gemini, DeepSeek

EU AI Act

Art. 50(1), Art. 50(2)

WhatsApp Business AI

Guest & Tenant Communication

Limited Risk

AI-powered WhatsApp messaging for guest communication. Handles check-in queries, property information, and booking management via WhatsApp Business API.

Data Processed
WhatsApp messagesphone numbersbooking contextproperty information
Autonomy Level

Autonomous with Review

Human Oversight

All WhatsApp conversations are accessible in the admin Unified Inbox. Human takeover available at any time. Operating hours enforced; out-of-hours messages queued for review.

AI Providers

Groq (Llama), Google Gemini, OpenRouter

EU AI Act

Art. 50(1), Art. 50(2)

AI Office (Admin Chat Assistant)

Internal Operations

Limited Risk

AI-powered chat assistant for property management staff. Provides operational insights, drafts communications, executes management tasks, and answers questions about properties, tenants, and finances.

Data Processed
platform datatenant recordsproperty datafinancial data
Autonomy Level

Autonomous with Review

Human Oversight

Used exclusively by authorised property management staff. All tool executions are logged in ai_agent_execution_logs. High-risk actions (rent notices, GDPR deletion, payment execution) require explicit human approval.

AI Providers

DeepSeek, Groq (Llama), OpenRouter, Google Gemini

EU AI Act

Art. 50(1), Art. 50(2)

SpareRoom AI Reply Bot

Property Marketing

Limited Risk

AI system that automatically responds to SpareRoom enquiries on behalf of property managers. Drafts responses to room enquiries, qualifies applicants, and books viewings.

Data Processed
enquiry messagesapplicant informationroom detailsavailability data
Autonomy Level

Autonomous with Review

Human Oversight

All AI replies are visible in the SpareRoom conversation log. Property managers can override responses. Viewing requests require human confirmation before booking confirmation is sent.

AI Providers

Groq (Llama), DeepSeek, OpenRouter

EU AI Act

Art. 50(1), Art. 50(2)

AI Blog Content Generation

Content & Marketing

Limited Risk

AI system that generates blog articles and industry news summaries for the Social Home website. Content is reviewed and published by staff.

Data Processed
topic promptsindustry datacompany information
Autonomy Level

Autonomous with Review

Human Oversight

All AI-generated content is reviewed by a human editor before publication. AI-generated content is tagged internally. Published articles may include an AI-assistance disclosure.

AI Providers

Groq (Llama), Google Gemini, DeepSeek

EU AI Act

Art. 50(3), Art. 50(4)

AI Social Media Automation

Content & Marketing

Limited Risk

AI system that generates and schedules posts for social media platforms (Facebook groups, LinkedIn) on behalf of property managers and the Social Home brand.

Data Processed
property detailsavailability databrand guidelines
Autonomy Level

Autonomous with Review

Human Oversight

Posts are generated using pre-approved templates and reviewed before scheduling. Managers can pause, edit, or delete scheduled posts at any time via the Social Media dashboard.

AI Providers

Groq (Llama), Google Gemini, OpenRouter

EU AI Act

Art. 50(3), Art. 50(4)

AI Tenancy Agreement Drafter

Document Automation

Limited Risk

AI-assisted generation of tenancy agreements (AST, HMO, Social Housing, Supported Housing). Populates standard templates with tenant and property data and produces a reviewable draft.

Data Processed
tenant personal dataproperty detailstenancy termsfinancial arrangements
Autonomy Level

Draft Only

Human Oversight

Agreements are produced as drafts only. A property manager must review and authorise before the document is sent for signature. Signatories can query any clause before signing.

AI Providers

Groq (Llama), Google Gemini, DeepSeek

EU AI Act

Art. 50(3)

AI Listing Content Generator

Property Marketing

Limited Risk

AI system that generates and optimises property listing descriptions for multiple platforms (Zoopla, SpareRoom, Airbnb, Booking.com). Analyses listing completeness and suggests improvements.

Data Processed
property detailsphotosamenitiespricing data
Autonomy Level

Draft Only

Human Oversight

Generated content is presented to the property manager for review before publishing. No AI content is published automatically without approval.

AI Providers

Groq (Llama), Google Gemini, OpenRouter

EU AI Act

Art. 50(3)

High Risk

AI Systems Affecting Housing & Finances

EU AI Act Annex III — These systems may influence decisions about access to housing, financial arrangements, or personal assessments. We are required to maintain human oversight, keep decision logs, and provide you with the right to request a human review. Full compliance deadline: 2 August 2027.

What this means for you: No high-risk AI system makes final decisions that affect your housing, finances, or rights without a human reviewing the outcome. You may request a human review of any AI-assisted recommendation affecting you.

Tenant Arrears Prediction

Tenant Assessment

High Risk

AI system that analyses payment history, engagement patterns, and property data to predict which tenants are at risk of falling into arrears. Results inform early intervention decisions.

Data Processed
payment historycommunication recordstenancy dataproperty data
Autonomy Level

Assisted

Human Oversight

Arrears risk scores are advisory only. A property manager must review all flagged cases before any action (letters, calls, formal notices) is taken. No automatic enforcement actions are triggered by AI alone.

AI Providers

Groq (Llama), Google Gemini, DeepSeek

EU AI Act

Art. 26, Art. 27, Annex III §5

Dynamic Pricing System

Revenue Management

High Risk

AI-powered pricing engine that analyses occupancy, competitor rates, seasonal patterns, and demand signals to recommend and (when enabled) automatically apply pricing changes to short-let properties across booking channels.

Data Processed
booking historyoccupancy datacompetitor pricingchannel availability
Autonomy Level

Autonomous with Review

Human Oversight

Auto-apply requires explicit opt-in per property. All pricing changes are logged with before/after values. Property managers can disable auto-apply at any time. Rollback available for any pricing run.

AI Providers

Groq (Llama), Google Gemini, DeepSeek

EU AI Act

Art. 26, Art. 27, Annex III §5

AI Booking Manager

Short-Let Operations

High Risk

AI system that processes booking enquiries, checks availability, calculates pricing, and creates provisional bookings. Handles cross-property sibling availability for overflow scenarios.

Data Processed
availability calendarspricing rulesguest detailsbooking history
Autonomy Level

Autonomous with Review

Human Oversight

Provisional bookings require host confirmation before being marked as definite. Pricing is surfaced to the guest transparently. Dispute and cancellation mechanisms are available.

AI Providers

Groq (Llama), Google Gemini, OpenRouter

EU AI Act

Art. 26, Art. 27, Annex III §4, Annex III §5

Guest KYC Document Scanning

Identity Verification

High Risk

AI vision system that reads and validates identity documents submitted during the guest check-in process (passports, driving licences, visas). Used for right-to-rent and fraud prevention checks.

Data Processed
identity documentsfacial images (selfies)document metadata
Autonomy Level

Assisted

Human Oversight

KYC results are presented to a staff member for human verification before access decisions are made. Guests may dispute any rejection and request a manual review. Data is retained only as long as legally required.

AI Providers

Groq (Whisper / Vision), OpenRouter (vision models)

EU AI Act

Art. 26, Art. 27, Annex III §1

Tenant Application ID & Selfie Verification

Identity Verification

High Risk

AI vision system that reads identity documents and compares a live selfie against the ID photo for applicants during the tenancy application flow (separate from guest check-in KYC above). Produces a confidence score used to route the outcome.

Data Processed
identity documentsfacial images (selfies)liveness-check video framesdocument metadata
Autonomy Level

Autonomous with Review

Human Oversight

Confidence 60-84% (manual review) and confidence <60% (AI-recommended reject) both route to a staff member, who must explicitly reject before an applicant is told to resubmit documents — no rejection is finalised on the AI score alone. Confidence ≥85%: as a deliberate business decision the system still advances the application automatically (creates a held tenant, sends the deposit request) with no prior human review step; this remains a known gap for the ≥85% band specifically and is not yet remediated. Applicants may always contact support to request human review of any outcome.

AI Providers

OpenRouter (vision models), OpenAI (GPT-4o fallback)

EU AI Act

Art. 14, Art. 26, Art. 27, Annex III §5

Tenant Income & Affordability Verification

Identity Verification

High Risk

AI vision system that extracts income figures from payslips, bank statements, Universal Credit statements, and tax documents submitted during the tenancy application, and produces an advisory affordability signal for staff.

Data Processed
payslips and bank statementsbenefits/Universal Credit statementstax documentsextracted income figures
Autonomy Level

Assisted

Human Oversight

Advisory only — the system's output never advances or blocks an application by itself; only a staff member's explicit approve/reject action changes application status. Staff guidance explicitly warns against rejecting solely on income figures. Applicants may request human review of any outcome.

AI Providers

OpenRouter (vision models)

EU AI Act

Art. 14, Annex III §5(b)

Tenant Applicant Scoring

Identity Verification

High Risk

Decision-support score (0-100) combining affordability, income stability, KYC status, right-to-rent status, and referencing to help staff triage tenancy applications. Benefits/pension income is scored at parity with employment income.

Data Processed
affordability ratioincome stability signalKYC and right-to-rent statusreferencing outcome
Autonomy Level

Assisted

Human Oversight

Decision-support only — the score is recomputed and persisted after a staff member's approve/reject decision, and never gates the decision itself. Displayed to staff with an explicit "decision-support signal only" label. Not used for any solely-automated decision under GDPR Art. 22.

AI Providers

In-house scoring — no external AI provider

EU AI Act

Art. 14, Annex III §5(b)

DBS & HHSRS Compliance Assessment

Compliance & Safeguarding

High Risk

AI-assisted assessment of DBS certificate validity, training compliance status, and HHSRS housing hazard scoring. Flags compliance gaps and generates compliance reports.

Data Processed
DBS certificate datatraining recordsproperty inspection data
Autonomy Level

Assisted

Human Oversight

All compliance assessments are advisory. A compliance officer must review and sign off on any compliance reports or enforcement actions. Tenants and contractors can challenge any assessment.

AI Providers

Groq (Llama), Google Gemini

EU AI Act

Art. 26, Art. 27, Annex III §8

Vulnerability & Benefit Assessment

Tenant Assessment

High Risk

AI system that analyses tenant data to identify potential vulnerability indicators, benefit eligibility signals, and support needs for social housing and supported living placements.

Data Processed
tenancy datasupport notesreferral informationfinancial data
Autonomy Level

Assisted

Human Oversight

All vulnerability flags are advisory and reviewed by a social housing professional before any decisions affecting a tenant's housing or support are made. Tenants have the right to request human review of any assessment.

AI Providers

Groq (Llama), Google Gemini, DeepSeek

EU AI Act

Art. 26, Art. 27, Annex III §5

Minimal Risk

Internal Tools & Analytics

These AI tools are used internally for analytics, transcription, and internal insights. They do not make decisions that directly affect you and have no mandatory EU AI Act obligations.

Property Valuation ML

Analytics & Insights

Minimal Risk

Machine learning model that estimates property values based on comparable sales data, location, and property characteristics. Used internally for portfolio reporting.

Data Processed
property characteristicslocation datamarket data
Autonomy Level

Assisted

Human Oversight

Valuations are estimates only, clearly labelled as AI-generated. Property managers are instructed not to use them as the sole basis for pricing or lending decisions.

AI Providers

Internal ML model (scikit-learn), Groq

AI Insights & Analytics

Analytics & Insights

Minimal Risk

AI-powered analytics dashboard providing property managers with occupancy trends, maintenance cost analysis, tenant satisfaction insights, and predictive KPIs.

Data Processed
aggregated platform dataoccupancy recordsfinancial summaries
Autonomy Level

Assisted

Human Oversight

Insights are informational only. No automated actions are triggered by analytics outputs. All recommendations require human review before implementation.

AI Providers

Groq (Llama), Google Gemini, DeepSeek

Voice Call Transcription

Internal Operations

Minimal Risk

AI transcription of voice calls for the admin call log. Converts recorded calls to text for record-keeping and searchability.

Data Processed
voice recordingscaller identity
Autonomy Level

Autonomous with Review

Human Oversight

Transcripts are reviewed by property managers for accuracy. Callers are informed their call may be recorded at the start of AI-handled calls.

AI Providers

Groq (Whisper Large v3), OpenRouter (Whisper)

Your Rights Under EU AI Law

Right to Know

You have the right to know when you are interacting with an AI system. When you communicate with our AI concierge (SMS, voice, email, or WhatsApp), you will be informed that you are speaking with AI at the start of the interaction.

Right to Explanation

If an AI system contributed to a decision affecting you (such as a tenancy recommendation, pricing change, or compliance assessment), you may request an explanation of how the AI reached its output. We will respond within 30 days.

Right to Human Review

For any high-risk AI system listed above, you have the right to request that a human member of staff reviews the AI's output before any decision affecting your housing, finances, or personal circumstances is finalised.

Right to Object and Appeal

You may object to any AI-assisted decision and request that it be reconsidered. You may also lodge a complaint with the Information Commissioner's Office (ICO) if you believe your rights under AI or data protection law have been infringed.

Compliance Status

RequirementStatusDeadline
Art. 50 — AI chatbot disclosure at interaction start Complete2 August 2026
Art. 50 — AI Transparency page published Complete2 August 2026
Art. 50 — Terms of Service AI disclosure section Complete2 August 2026
Art. 50 — Privacy Policy AI processing section (GDPR Art. 22 alignment) Complete2 August 2026
Art. 26/27 — FRIA (Fundamental Rights Impact Assessment) for high-risk systemsIn Progress2 August 2027
Art. 12 — 6-month AI decision log retention (all high-risk systems) Complete2 August 2027
Annex IV — Technical documentation for high-risk AI systemsIn Progress2 August 2027
Vendor compliance — DPAs and AI Act compliance confirmations from AI providersIn Progress2 August 2027

Contact & Complaints

AI Compliance Contact

For AI-related enquiries, right-to-explanation requests, or to request human review of an AI-assisted decision:

Kunda House Limited

Email: ai-compliance@social-home.co.uk

We will respond within 30 days.

Regulatory Complaints

If you believe we have breached the EU AI Act or UK data protection law, you have the right to complain to:

Information Commissioner's Office (ICO)

Website: ico.org.uk

Email: casework@ico.org.uk

For general data protection queries, visit our Privacy Policy or our GDPR Rights page. For general terms, see our Terms of Service.

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