The Tool Desk
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A campaign AI policy should say which tools and uses are allowed, who approves higher-risk work, what data staff may enter, how public content is checked and disclosed, and what to do when suspected AI disinformation appears. Start by naming an owner and inventorying current uses, then set review gates and have local election-law and privacy counsel check the policy before adoption. Requirements depend on where the campaign operates, its organizational status, the medium, and the specific use.
Start with a named owner and a clear scope
Assign one person to maintain the policy and a deputy who can handle time-sensitive approvals. The owner might be a campaign manager, operations lead, or compliance lead; what matters is that staff know who is accountable. Define which staff, volunteers, contractors, vendors, accounts, and devices are covered, and state what the campaign means by “AI” for policy purposes. Include generative tools as well as AI features embedded in ordinary software.
NIST’s voluntary AI Risk Management Framework organizes risk work into four functions: Govern, Map, Measure, and Manage. Its guidance supports assigning responsibilities, documenting applicable legal requirements, and maintaining an inventory. NIST says its framework is under revision, so treat it as an operating aid—not law, a certification, or a legal safe harbor.
Inventory the campaign’s AI uses
Before approving a tool or use, record enough information to understand what it does, what information it handles, and who is responsible for its output. Maintain one register that campaign leadership can review and update.
| Register field | What to record |
|---|---|
| Tool and provider | Product or service name, vendor, account type, and any relevant vendor terms. |
| Use and user | Purpose, responsible staff member or contractor, intended audience, and whether the output is internal or public-facing. |
| Data and handling | Types of information entered, retention and deletion settings, and whether the provider may use inputs or outputs for other purposes. |
| Output and review | Output type, named human reviewer, approval date, required checks, and where the approved version is kept. |
| Disclosure and changes | Whether a disclosure may be required, what was disclosed, and any material changes to the tool, vendor, or use. |
Make separate entries when one product is used in materially different ways. Useful campaign categories include drafting, translation, transcription, design, image/audio/video generation, voter-facing chat, analytics and targeting, fundraising, and internal operations. These are practical inventory categories, not a legal classification.
Set review gates by risk and audience
A policy should make ordinary work easy without allowing consequential or deceptive uses to slip through. The following tiers are a recommended design, not a universal legal rule. Adapt them to the campaign’s jurisdiction, channels, and staffing.
| Tier | Examples | Minimum gate |
|---|---|---|
| Routine internal assistance | Formatting notes, summarizing non-confidential material, or drafting internal schedules. | Use an approved service, keep prohibited data out, and have the staff user check the result before relying on it. |
| Public factual communication | Drafting a policy statement, translating a public post, or preparing fundraising copy. | A named manager checks facts, sources, names, dates, context, permissions, and any disclosure need before release. |
| Elevated or sensitive use | Synthetic depictions or voices of real people, voter-facing AI, targeting, claims about opponents, or voting-procedure information. | Require documented approval from senior communications and compliance leads, plus legal review when warranted, before use. |
Write prohibited uses explicitly. At minimum, prohibit fabricated endorsements, impersonation, knowingly false voting details, and deceptive synthetic material. Identify who can grant an exception, if any, and require that the exception be documented; some conduct should remain prohibited regardless of approval.
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Require a human check before publication or consequential use
A human reviewer must own the decision to publish or act on an AI-assisted output. A tool’s confident wording, citations, or polished appearance is not evidence that its content is accurate. For each reviewed item, check:
- Whether factual claims are supported by reliable source material and accurately represented.
- Names, dates, quotations, and voting information, including details that can change by location or election.
- Whether the campaign has permission to use the source material, likeness, voice, or other protected content.
- Whether the output could unfairly target or mischaracterize people, or create a misleading impression in context.
- Whether applicable law, platform rules, or campaign policy requires a disclosure.
Keep the material needed to reconstruct the decision: relevant source material, the output reviewed, the final approved version, reviewer, and approval date. NIST’s AI RMF recommends context-sensitive assessment and risk management across an AI system’s lifecycle; its guidance does not prescribe a campaign-specific approval ladder.
Check disclosure and election rules for each use
Do not treat “AI-generated” as one legal category. Rules can depend on jurisdiction, campaign or committee status, sponsor, medium, content, whether a real person or event has been altered, and whether a platform has its own labeling requirement. A platform label does not necessarily satisfy a legal duty, and a legal disclosure may not satisfy platform rules. Have local election-law counsel review the intended use and channel before publication.
| Context | What the cited authority says | Practical limit |
|---|---|---|
| United States federal campaigns | In its September 2024 interpretive-rule summary, the Federal Election Commission said federal fraudulent-misrepresentation law is technology-neutral and can apply to AI-assisted media. The Commission did not open a separate rulemaking on AI campaign ads. | This describes federal law, not every state or local rule. The FEC’s general disclaimer page says political committees generally must include clear and conspicuous disclaimers on public communications, but the page warns it has not been revised to reflect the Supreme Court’s June 30, 2026 decision. Check current requirements rather than relying on that page alone. |
| European Union | The European Commission’s guidance on the AI Act says Article 50 transparency obligations apply from August 2, 2026, including notice obligations for deepfakes and certain public-interest text generated or manipulated by AI without human review or editorial control. The EU’s political-advertising regulation separately addresses transparency and targeting. | These are distinct frameworks. Determine whether the campaign, communication, and service fall within each applicable rule; do not assume one disclosure covers both. |
| India | In May 2024, the Election Commission of India directed political parties and representatives to refrain from circulating deepfake audio/video and patently false or misleading information. It directed covered parties to remove specified content promptly, within three hours of notice. | The direction and timeframe are specific to the covered parties and context in India. They are not a general deadline for campaigns elsewhere. |
These examples illustrate why a policy needs a jurisdiction-specific disclosure checklist rather than one global sentence. For the campaign’s actual footprint, list the applicable election, privacy, advertising, and platform requirements, then identify who confirms them for each channel and sponsor.
Protect voter, donor, staff, and strategy data
Set a data boundary that workers can follow under deadline pressure. Use approved services and accounts for campaign work, and do not enter voter, donor, employee, or confidential strategy data into an unapproved AI service. Before approving a provider, check its data-use, storage, access, retention, and deletion settings and decide who may use the account.
UK government election-security guidance recommends official devices and communications for campaign work, strong passwords, two-step verification, and learning how to report content through platform processes. These are useful security practices, but that guidance is not a substitute for the campaign’s own local legal and security review.
Prepare a response path for suspected AI disinformation
Decide in advance who assesses an incident and who is allowed to speak publicly. A simple response path is:
- Preserve evidence: Record the URL and time, capture the content and relevant context, and store the evidence securely. Avoid editing the original capture.
- Assess potential harm: Determine whether the content impersonates someone, could affect safety or reputation, or gives false voting information. Escalate urgent voting-information risks immediately.
- Notify the designated leads: Contact the communications owner and legal or compliance lead, using the campaign’s internal incident channel.
- Report through the right channels: Use the platform’s reporting process and notify any relevant party or election authority as appropriate to the jurisdiction.
- Decide whether a public response helps: Do not repost or quote suspected false content if doing so would amplify it. If a response is needed, use official campaign channels and have the designated approver clear it.
UK government guidance for electoral candidates and officials says, “Think before you respond to any reports of disinformation.” The operational point is to preserve, assess, and route the incident before reacting publicly; the campaign should not improvise a response that gives the false content a wider audience.
Train people, log decisions, and revisit the policy
Train staff, volunteers, and contractors on approved tools, data restrictions, review gates, disclosure checks, and incident reporting. Keep a decision log for approvals, exceptions, disclosures, complaints, incidents, and corrections. Set a review schedule that fits the election calendar, and reopen the review whenever a tool, vendor, law, or use case materially changes. NIST calls for periodic review and continuing risk management, but does not set a campaign-specific review interval.
Choose the policy trade-offs deliberately
There is no single approval model that fits every campaign. Record the reason for the chosen balance so staff understand when speed is appropriate and when review is mandatory.
| Policy choice | What it favors | What to weigh |
|---|---|---|
| Routine-use approval | Pre-approval for every use creates more control; allowing low-risk routine tasks with user review is faster. | Compare the value of speed with factual, legal, and reputational risk, and keep public or sensitive uses behind a stronger gate. |
| Disclosure standard | A campaign may limit disclosures to those legally required or adopt a more transparent voluntary standard. | Account for jurisdiction and platform duties, audience trust, and the risk that an unlabeled synthetic item misleads people. |
| Approved-tool boundary | Approved services with reviewed data terms provide more control than unrestricted use of public tools. | Compare confidentiality, retention, access, and cost; do not assume a tool’s public availability makes it appropriate for campaign data. |
| Incident authority | Centralized communications/legal approval promotes consistent messaging; delegated local authority can be faster. | Specify which incidents can be handled locally and which require central escalation, especially when voting information or a real person is involved. |
Put the policy into a usable approval workflow
A short workflow makes the written rules operational. Use the following sequence for each new tool or materially new use:
- Submit: The user records the tool, purpose, audience, data involved, and proposed output in the AI-use register.
- Classify: The policy owner assigns a risk tier based on public impact, data sensitivity, likelihood of deception, and applicable jurisdiction or channel.
- Review: The designated manager, communications lead, compliance lead, or counsel completes the tier’s approval checks and records the decision.
- Use and verify: The user stays within the approved purpose and data boundary; the named reviewer checks output before publication or consequential use.
- Log and revisit: Store the final version and approval record, then reassess if the tool, vendor, audience, law, or purpose changes.
Before adoption, ask a local election-law and privacy professional to review the policy against the campaign’s jurisdiction, organizational form, likely uses, and intended channels. The U.S. Election Assistance Commission’s AI resources are directed primarily at election officials and election administration; they do not establish campaign policy requirements.
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