Independence is a structure, not a stated intention. This document sets out the structure: what the firm is unable to sell, how it differs from every other provider of AI and data assurance, how each person on an engagement is vetted for that engagement, and the route open to anyone who believes the policy has not been followed.
Most AI and data assurance is sold by the people who built, deployed or resold the system under review. The vendor needs the model trusted. The platform needs the dashboard believed. The integrator needs the remediation programme that a finding creates.
Insight Circle builds no models and licenses no platforms. We hold no commercial position in anything a finding of ours could lead a client to buy, keep, replace or write off. That absence is not a promise about our conduct; it is a description of what the firm is, which is the only reason our opinion is worth anything to a board, a regulator or an investor.
1.1 This policy governs every engagement accepted by Insight Circle, every person who works on one, and every publication the firm issues. There is no category of work to which it does not apply.
1.2 It is incorporated by reference into every engagement letter. Where an engagement letter and this policy conflict, this policy prevails.
1.3 It is published rather than held internally so that a client, a regulator or a counterparty can hold us to a standard they can read, and so that any departure from it is visible.
1.4 Nothing in this policy limits a client's rights under the engagement letter or at law.
2.1 Engagement means any assurance, diagnostic, index or advisory assignment accepted by the firm, whether or not a fee is charged.
2.2 Vendor means any supplier of technology, models, platforms, data, certification or implementation services, including any entity within the same group.
2.3 Engagement team means every person assigned to an engagement, in any capacity.
2.4 In scope means within the boundary of the systems, data, models and controls named in the engagement letter.
2.5 Finding means any conclusion, score, rating or opinion the firm records or publishes.
3.1 The firm sells independent assurance, an independent index, and the analysis that follows from them. It sells nothing that a finding could lead a client to buy.
3.2 The firm does not, and under this policy may not:
3.3 An assurance engagement ends with the answer. It does not end with a programme to deliver.
3.4 Clauses 3.1 to 3.3 are constraints on the firm's business model rather than undertakings about future behaviour. That is why they hold.
4.1 Every other category of provider in this market earns revenue from something the client may buy, retain or expand as a consequence of the opinion given. The table below states the structural position of each, without naming firms.
| Provider | What else they sell to the same client | Why the opinion is compromised |
|---|---|---|
| Vendor or model developer | The model, tool or system under review, plus licences and renewals | An adverse finding reduces the value of the asset they are selling. They cannot report against their own product. |
| Cloud or platform provider | The infrastructure the system runs on, metered by consumption | Their revenue rises with workload. Recommending that a workload be withdrawn is against interest. |
| Systems integrator or implementation consultancy | The original build, and the remediation programme that follows a finding | A finding is the sales pipeline for the next phase, and frequently audits their own prior work. |
| Audit or accountancy firm with an advisory arm | Advisory, transformation, managed services and technology resale to the same account | The assurance fee is the entry point to a larger relationship. Independence is managed internally rather than structurally absent. |
| Certification body or compliance-tooling provider | A licence, a badge, a platform subscription or a recurring audit cycle | The product is the certificate. Withholding it withholds the revenue. |
| Insight Circle | Nothing. We build no models and license no platforms. | There is no second sale to protect. Our fee is identical whether the answer is favourable or not. |
The table describes commercial structures, not the integrity of any individual or firm. Competent, honest people work in all five categories. The point is that a board cannot verify integrity, and should not have to: it can verify structure.
4.2 It follows that the firm will decline work that other providers would accept, including: assurance over a system the firm had any hand in selecting; remediation of a failure the firm itself identified, save under clause 7; and any engagement whose scope is set by the party whose work is being assessed.
4.3 The firm does not describe itself as independent on the basis of internal separation, ethical walls, rotation policies or a code of conduct. Those are controls applied to a conflict that exists. This policy removes the conflict.
5.1 Every person assigned to an engagement is vetted for that engagement. One standard applies to everyone on the team, without distinction of seniority, role, or contractual relationship with the firm. Vetting is not performed once and then relied upon thereafter.
5.2 Vetting is performed before the person is assigned, and is assessed against the named client, the named systems and the named vendors in scope. It covers, as a minimum:
5.3 Assignment is approved centrally by the firm and is never delegated to the engagement itself, so that no person selects the assessor of their own recommendation.
5.4 A declaration that cannot be cleared, or a refusal to declare, ends that person’s assignment. It does not end the engagement, and no cost arising from it passes to the client.
5.5 The client is told who will work on its engagement before work begins — each person’s background, the seat they have held, and the basis on which they are engaged — and may decline any individual, without giving a reason and at no cost.
Accountability does not vary from one member of the team to another. Every engagement is scoped, led, reviewed and signed by Insight Circle. The client contracts with the firm, every person on the team is covered by the firm’s professional indemnity insurance, and recourse is against the firm. No individual is ever the client’s counterparty.
5.6 The firm does not sell time. Engagements are fixed in scope and in price before work begins, so no one on a team carries a utilisation target and no finding creates a commercial reason to extend.
5.7 On written request, a client may see the vetting record for any person assigned to its engagement, redacted only where disclosure would breach a third party’s confidence.
6.1 Conflicts are declared and recorded before scoping begins, not at the point of reporting. The firm maintains a conflict register covering the firm, its principals, and every person assigned to an engagement.
6.2 The firm declines any engagement in which it holds a commercial interest in a vendor in scope.
6.3 Where a conflict emerges during an engagement, the firm discloses it to the client in writing within five working days and the client may terminate without further fee.
6.4 No single client may represent a share of annual fee income at which the firm's conclusions could reasonably be doubted. Concentration is monitored and reported to the advisory board.
6.5 Gifts, hospitality and paid speaking from vendors are refused, not disclosed-and-accepted.
7.1 Assurance and index work routinely surfaces problems a client then wants help to solve. That is the precise structure criticised at clause 4, so the firm separates it explicitly rather than relying on good intentions.
7.2 No person involved in assessing or scoring an organisation is compensated, directly or indirectly, on any work that follows from the finding.
7.3 Follow-on work is undertaken only where the client asks for it, never where the firm has offered it alongside a finding.
7.4 Any follow-on work is staffed separately from the assessment team, and the firm states in writing who assessed and who advised.
7.5 The firm does not provide assurance over its own advisory work, at any remove and at any point in the future.
8.1 Coverage is drawn from public sources and includes every significant participant in a sector, whether or not they are clients. No organisation pays to appear, and none can pay to be omitted or to alter its position.
8.2 There is no sponsor and no advertising. No section is underwritten and no vendor funds any part of the index.
8.3 Assurance maturity is measured, never inferred. A named organisation appears on that axis only where the firm holds survey data for it. The firm does not publish an opinion about an organisation's controls as though it were a measurement.
8.4 Sources, sample, instrument and method are published with every wave, including where the data was too thin to support a conclusion.
8.5 What a client buys is the explanation of its position and the drivers behind it. It does not buy the position itself, which is determined by the method alone.
8.6 Internal survey responses are collected anonymously and returned to the firm, never to the client's line management. Findings are reported to the board before any executive population.
9.1 FlexTrust is a verification method and data layer for customer-led flexibility, developed within Insight Circle and intended to be supported by public grant funding. It is not a commercial product and is not sold.
9.2 Public funding is the point rather than a footnote: it requires the method to be independently checkable from the outset, which is the standard the firm holds its clients to.
9.3 FlexTrust will be established as a separate entity. The firm does not provide assurance services to FlexTrust participants, and any engagement touching FlexTrust falls under clause 6 and is declined or disclosed accordingly.
10.1 The firm collects scored answers and evidence of control operation, not client records. No client data leaves the client's environment as part of an assessment unless the engagement letter expressly provides for it.
10.2 Diagnostic and index responses are held under ISO 27001 certified controls.
10.3 No cut of survey data with fewer than seven respondents is reported, at any stage, to anyone, including the commissioning client.
10.4 Individual organisation lines are never published, sold, or shown to another client. Participants are named as contributors only with written consent, and never against a score.
10.5 Engagement and vetting records are retained for seven years from completion, then destroyed. Privacy terms are set out in the privacy notice.
11.1 Any client, participant or survey respondent who believes this policy has not been followed may raise it directly and confidentially, in writing, to bookabriefing@insightcircle.com, marked Independence.
11.2 The firm acknowledges within two working days and responds substantively within ten.
11.3 Matters that remain unresolved are referred to the advisory board, which sits outside client engagements and takes no part in them.
11.4 Raising a concern never affects the delivery, scope or price of work already commissioned, and no respondent is identified to a client as the source of a concern.
12.1 This policy is reviewed annually, and additionally on any material change to the firm's structure, ownership or services. Each version is numbered and dated; superseded versions are retained and available on request.
12.2 Breaches are recorded, reported to the advisory board, and disclosed to any client affected.
12.3 The advisory board, drawn from regulated industries, tests the method, challenges conclusions that touch its members' sectors, and holds the firm to this policy. Its members take no part in client engagements.
12.4 Company registration details are published on the About page.