Novo Nordisk Foundation – Policy on Data Ethics
The Novo Nordisk Foundation is committed to upholding the highest standards of ethical conduct regarding the use of data, including compliance with Danish, EU, and other relevant laws. Additionally, recognising that the fast pace of technological development can leave regulatory gaps, we have further developed six principles for how to handle data in an ethical way.
This policy describes how the Novo Nordisk Foundation uses and processes data, including identifiable personal data, non-identifiable (e.g. anonymised) personal data, and data that grant applicants submit using the Foundation’s application system. The policy complements all other rules and guidelines for handling of personal and other data that apply to employees.
The overall responsibility for the policy on data ethics is anchored with the Foundation’s CFO. The Foundation will periodically review and revise the principles to reflect evolving technologies, the regulatory landscape, stakeholder expectations, and understanding of the risks and benefits to individuals and society of data use.
The six principles of the Novo Nordisk Foundation’s policy on data ethics and responsible handling of personal data are:
- Respect for the privacy of grant recipients, applicants and employees is a fundamental value for NNF.
- NNF considers data ethics considerations as more far-reaching than just compliance with the law.
- NNF prioritises openness and transparency in the ongoing challenge of ethically handling both personal data and non-identifiable data. NNF strives to learn from regulators, other companies, and other organisations.
- NNF minimises access to personal data to employees with a “need to know”. Employees with access to such data are bound to confidentiality.
- NNF only discloses grant applicant data to authorities if there is an obligation to do so according to legislation and a court or regulatory decision.
- Artificial intelligence, analyses, impact measurements, and the use of algorithms must be aligned with NNF’s core values and dedicated to advancing our strategy and goals. These can include assisting NNF’s grant applicants or recipients and promoting openness and transparency around NNF’s activities and impact. The Foundation maintains a separate Policy on Ethical Use of AI which expand on this point.
Policy on Ethical Use of AI
The Novo Nordisk Foundation is committed to upholding the highest standards of ethical conduct in the use of Artificial Intelligence (AI), including compliance with Danish, EU, and other applicable laws. In addition, recognising that the fast pace of technological development can leave regulatory gaps and requires thoughtful and responsible decision making, we have further developed this policy on ethical use of AI.
This policy covers NNF-related use of AI by employees, management, consultants, suppliers, and vendors. In addition, this policy covers grant applicants and recipients, personnel funded by NNF grants, members of NNF committees, peer reviewers and individuals, institutions, and organisations collaborating with us when carrying out activities funded by or related to NNF.
Guiding Principles
The following principles should guide the use of AI by individuals and organisations covered by this policy.
Societal benefit
Your use of AI must be aligned with NNF’s core values and dedicated to advancing our strategy and goals. In addition, any use of AI must fully comply with relevant legislation.
Transparency
You must be transparent in disclosing when and how AI is used in any decision-making processes.
Fairness
You must minimise use of AI that could lead to unfair discrimination against individuals or groups and actively seek out appropriately trained AI to avoid creating or reinforcing biases.
Safety
You must take steps to ensure that your use of AI does not pose unwanted harms to people or processes.
Data protection
You must make sure your use of AI accounts for the protection and security of data, as well as upholds privacy, confidentiality and intellectual property obligations.
Human autonomy and oversight
You must ensure that individuals maintain an ability to guide AI activities, decide when and how AI is applied, and review or override AI decision-making.
Accountability
Your use of AI does not diminish or transfer your responsibility – you remain fully accountable for all materials created with AI assistance.
AI Rules for Committee Members and Peer Reviewers in the assessment of grant applications
The Novo Nordisk Foundation’s Policy on Ethical Use of Artificial Intelligence (AI) reflects our commitment to transparency, fairness, data protection and accountability. In line with the European Commission’s Living Guidelines on the Responsible Use of Generative AI in Research, the following rules apply to all committee members and peer reviewers globally.
Prohibited uses of AI
You must not use any AI tool:
- to replace or delegate your own expertise and professional judgement; or
- in any way that may breach confidentiality, privacy or intellectual property obligations relating to grant applications.
Examples of prohibited uses include:
- using AI to evaluate, assess, score, compare or rank grant applications; or
- uploading or otherwise disclosing any grant application content to an AI tool.
Permitted uses of AI
You may use AI tools to access information or improve language, provided that:
- no grant application content or related confidential or personal information is entered; and
- the AI use does not substitute for your evaluative judgement.
Examples that may be acceptable include:
- help with grammar or spelling of text you have written;
- drafting generic administrative wording (e.g. standard phrases); or
- general explanations of concepts unrelated to a specific application.
Accountability
You remain ultimately responsible for your review and analysis – AI tools are neither authors nor decision-makers in the Foundation’s evaluation processes.
These rules will be reviewed regularly. Recognising the fast-evolving nature of AI technology, we welcome any questions or feedback – please contact [email protected].
