How we use Generative AI
Our Commitments
All use of Generative AI at Mills & Reeve is governed by eight core commitments, which apply to everyone at the firm, including our lawyers.
We do not share any information that is not already available in the public domain, nor personal data, with any public online GenAI model or software tool.
We only use online GenAI models or software tools that Mills & Reeve has assessed and approved in advance.
We critically assess all GenAI outputs for potential bias and factual inaccuracy. Any citation, statutory reference, case, guidance, or legal authority generated by GenAI is verified against a primary authoritative source before use in any work product.
We assess whether GenAI outputs may infringe intellectual property rights, in particular the copyright of third parties.
We do not directly replicate GenAI output in client documents, legal advice, or public materials without our people reading it and making it their own.
We do not rely on GenAI in time-sensitive situations where our people do not have adequate opportunity to apply appropriate oversight and verification.
We maintain evidence of human supervision and critical assessment of all GenAI outputs. All elements of work product involving AI assistance are identified and reviewed by a responsible lawyer or professional.
We always check whether a client has imposed any restriction on the use of GenAI in connection with their matter and comply with any such restriction. Our terms of business address our use of software including GenAI.
Introduction to Generative AI (GenAI)
GenAI is a type of artificial intelligence that can create new and unique content, such as text, images, and code, by learning from large datasets. Unlike other AI technologies that primarily identify patterns or support decision-making, GenAI can generate original outputs. It has the potential to enhance our capabilities and support the delivery of our legal services.
We are committed to using GenAI responsibly and in line with our professional obligations and Mills & Reeve’s values.
This statement explains how Mills & Reeve governs the use of GenAI to create, modify, or enhance content. It addresses the quality and oversight of AI outputs, legal and regulatory compliance, the role of professional judgement, ethical considerations, environmental impacts, and risk management.
1. Quality Assurance
GenAI tools are not always accurate or reliable. Their outputs are based on their training data and other available sources, which may be incomplete, outdated, inaccurate, or subject to bias. They may not have access to the most recent legal developments. For example, a GenAI tool without web access may be unaware of recent cases or legislation, whilst a GenAI tool with web access may locate inaccurate information online.
GenAI can also produce hallucinations: fabricated citations, legal authorities, events, or facts, presented as if they are genuine. There are well-documented cases of litigants and legal practitioners relying on fabricated or misquoted legal authorities generated by AI, with errors discovered only by a judge at trial or on review of filed papers. Accordingly, we do not solely rely on GenAI as a source for legal research or legal judgement. We require all GenAI output to be reviewed and validated against authoritative sources before being incorporated into any legal advice, documentation, or client communication. The individual and their supervisor remain responsible for any final content.
2. Legal Compliance
Our use of GenAI must comply with all applicable laws and regulations, and professional obligations governing the practice of law, the protection of personal data and the use of technology. The key legal and regulatory frameworks relevant to our use of GenAI include:
The Solicitors Regulation Authority (SRA) Standards and Regulations, which set out the ethical and professional obligations of solicitors and law firms in England and Wales, including the principles of integrity, competence, confidentiality, and acting in the best interests of clients. MIlls & Reeve is an SRA-regulated firm.
UK GDPR and Data Protection regulation, requiring personal data to be processed lawfully, fairly, and transparently, with appropriate technical and organisational measures in place to ensure security and accuracy.
Intellectual property laws, which protect the ownership and use of creative works. Our policy requires that our GenAI use does not infringe third-party intellectual property rights, and that the implications for the intellectual property of material input into a GenAI system are considered.
The EU AI Act (if applicable), which establishes a risk-based framework for the safe and ethical use of AI systems in the EU, aimed at ensuring that AI respects fundamental rights and values.
3. Professional Judgement
GenAI is not a substitute for professional legal reasoning and judgement. Whilst it may provide a useful starting point for research, drafting, or analysis, the process of identifying relevant law, assessing its applicability, and forming a legal view rests with the lawyer responsible for the matter. Our legal professionals bear ultimate responsibility for the conclusions they reach, any submissions they make and any legal work product sent to courts or clients.
We take particular care where GenAI is used in connection with any document, letter, or submission intended for a court or tribunal. Any statutory provision, rule, or case cited in such material must be verified against a primary authoritative source before it is filed or submitted. Where there is any question about the accuracy or appropriateness of AI-assisted content in material intended for a court or tribunal, team members are required to inform the supervising partner before submission.
Supervising and reviewing lawyers bear the same responsibility for AI-assisted work as for any other work. When reviewing work that involves legal citations, court submissions, or client advice, supervisors must actively enquire whether GenAI was used and whether outputs have been verified.
4. Ethical Principles
All GenAI used for Mills & Reeve business purposes is assessed against the following principles:
Privacy: GenAI should only use, create, or share personal data where a lawful basis for processing exists under the UK GDPR. All personal data processed by or through GenAI tools must be protected from unauthorised access or misuse.
Fairness: GenAI must not create or amplify bias or discrimination based on characteristics such as race, gender, age, disability, or religion. Any GenAI used to process personal data must do so in a manner that individuals would reasonably expect.
Transparency and accountability: GenAI should provide clear and accurate information about its sources, methods, limitations, and outputs, and allow for feedback and correction. We assess and record information about the GenAI tools we use, including their data protection and privacy implications.
Appropriate data use: All data used in connection with our GenAI tools is handled in accordance with our data protection and information security policies.
5. Environmental Considerations
Mills & Reeve recognises that the development and use of AI technologies can have environmental impacts and considers this as part of our SBTi (Science Based Targets Initiative) reporting. We are committed to responsible and sustainable AI use that supports our wider environmental goals, including the adoption of energy-efficient technologies and the responsible selection of AI suppliers.
6. Approved GenAI Tools
We maintain a curated list of GenAI tools that have been approved for use within the firm. Our approved tools span several categories, including: AI-assisted legal research tools; document review and summarisation tools; general AI chat assistants accessed through secure, firm-controlled environments; and AI capabilities integrated within our existing software applications. New tools are only added to the approved list following assessment and approval. In particular:
Approved GenAI tools do not allow our inputs (prompts) or system responses to be used to train models.
Tools approved for use with our own or our clients’ confidential information include additional confidentiality/privacy safeguards.
7. Risk Management
We take a proportionate approach to risk in our use of GenAI. Higher-risk applications, including any automated or agentic workflows involving reduced human oversight, require greater scrutiny, verification, and senior supervision before and during use. Individuals are provided with training and guidance to support their knowledge and understanding of the risks associated with the use of GenAI and what to do if errors occur.
8. Review and Updates
This statement will be reviewed regularly alongside our internal guidance to Mills & Reeve colleagues, to keep pace with technological advances and changes in law, professional regulation and best practice.
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