AI Usage & Data Governance Policy – SturdyCloud IT Ltd.
Effective Date: April 2, 2026
Last Updated: July 6, 2026
Legal Entity
For this policy, SturdyCloud IT Ltd. is the company legal name and the responsible legal entity unless a separate written agreement states otherwise.
Where this policy uses “SturdyCloud,” “we,” “our,” or “us,” it refers to SturdyCloud IT Ltd. and its websites, platforms, services, AI-enabled workflows, and client-facing systems.
1. Purpose
This AI Usage & Data Governance Policy outlines how SturdyCloud IT Ltd. ("SturdyCloud") designs, deploys, and manages artificial intelligence (AI) systems responsibly.
Our goal is to ensure AI is used in a way that is:
- Secure
- Transparent
- Accountable
- Human-centred
- Privacy-aware
- Accessible
This policy applies to all AI-powered tools, platforms, workflows, and services provided by SturdyCloud.
2. Scope of AI Systems
This policy applies to:
- AI-powered applications, including ProposalZen or similar systems
- AI Office Setup and AI Office Support workflows
- AI Office Extension call-answering, support, booking, lead qualification, payment reminder, and logistics workflows
- AI Operations Partner systems
- AI-native B2B SaaS products and client-specific AI software
- AI agents and assistants
- Workflow automation systems with AI components
- Content generation, summarisation, and decision-support tools
- Retrieval-augmented generation, document analysis, and knowledge-base workflows
- Integrations with third-party AI providers or self-hosted AI models
3. Core Principles
a. Human Oversight
AI is designed to support—not replace—human decision-making.
- Human review is required before any material action is taken.
- Users retain full responsibility for decisions.
- High-risk workflows require clearer review, escalation, and approval points.
b. Transparency
- Users are informed when AI is used where practical and appropriate.
- Limitations of AI systems are disclosed.
- Client-specific workflows should document where AI is used and what data it processes.
c. Accountability
- AI systems include safeguards and guardrails.
- Outputs and workflows are monitored for misuse or unintended behaviour where support scope allows.
- Prompt, configuration, and workflow changes should be tracked where appropriate.
d. Privacy & Data Protection
AI systems are designed to minimise and protect data usage.
- Data collection is limited to what is necessary.
- Processing aligns with applicable laws, including PIPEDA.
- Where applicable, processing should be GDPR-aware and documented for client-specific requirements.
- Sensitive or regulated data should not be submitted unless approved under a secured engagement.
e. Security
- Secure infrastructure
- Controlled access
- Monitoring and logging
- Secrets management
- Least-privilege access
- Separation between public demo data and client data
f. Fairness & Responsible Use
- Avoid harmful, misleading, or discriminatory outputs.
- Promote lawful and ethical use of AI.
- Avoid using AI systems to create deceptive, manipulative, harassing, discriminatory, or unlawful content.
g. Accessibility
AI-enabled experiences should be designed with WCAG 2.2 AA as the development target where applicable.
4. AI Risk Classification
SturdyCloud categorizes AI use cases based on risk level.
Low Risk
- Content drafting
- Internal summaries
- Productivity tools
- Internal brainstorming
- Non-sensitive prompt libraries
Medium Risk
- Client-facing outputs
- Workflow recommendations
- Automated suggestions requiring review
- Customer support drafts
- Lead qualification support
- Scheduling or routing suggestions
High Risk
- Regulated workflows
- Sensitive data processing
- Actions with financial, legal, employment, health, safety, procurement, or operational impact
- Voice or call-answering systems that collect sensitive information
- Automated customer-impacting decisions
Higher-risk use cases require stricter controls, validation, and human oversight.
5. AI Use Case Review & Approval
Before deployment, AI use cases are evaluated to ensure:
- appropriate use of data
- alignment with privacy and security expectations
- suitability for the intended business purpose
- presence of human review checkpoints
- accessibility considerations for users who interact with the system
- CASL-aware consent and unsubscribe handling for outreach or messaging workflows
- GDPR-aware handling where EU/EEA, UK, or international personal data may be in scope
Use cases may be adjusted, restricted, or declined if they introduce unacceptable risk.
6. Data Handling & Usage
a. User Data
Users may submit:
- Business data
- Documents and workflows
- Structured or unstructured content
- Support requests and customer communications
- Call, booking, or scheduling details where applicable
Users are responsible for ensuring they have the right to use and submit this data.
b. Data Processing
Data is processed only to:
- deliver services
- generate outputs
- improve system reliability and performance where appropriate and lawful
- troubleshoot and secure workflows
- maintain records required for support, billing, auditability, or compliance
c. Sensitive Data
Unless explicitly agreed under a secured engagement:
- users should not submit highly sensitive or regulated data
- SturdyCloud does not assume responsibility for unauthorised sensitive data input
- AI workflows should be designed to minimise exposure of sensitive data
d. Data Retention
- Data is retained only as necessary.
- Users may request deletion or export of their data, subject to legal, contractual, technical, backup, security, and operational obligations.
7. AI Model & Vendor Governance
SturdyCloud may use third-party AI providers or self-hosted AI models.
We:
- evaluate providers based on security, reliability, and data handling practices
- decline participation in model training on client data whenever possible
- prioritise Canadian data residency where feasible
- notify Canadian clients when data residency outside Canada is required for a given service or provider where appropriate
- consider provider terms, retention settings, logging, and training practices where relevant
- document client-specific restrictions where agreed
8. CASL-Aware AI Communications
AI and automation may be used to help draft, personalize, route, schedule, or send electronic communications.
Where CASL applies, AI-assisted commercial electronic messages should include:
- appropriate consent or another lawful basis
- accurate sender identification
- contact information
- unsubscribe functionality where required
- suppression of contacts who have opted out
- human review for higher-risk or sensitive campaigns
Clients remain responsible for ensuring their contact lists, consent records, campaign instructions, and message content comply with applicable law.
9. GDPR-Aware AI Processing
Where GDPR or similar international privacy laws apply, AI workflows should consider:
- lawful basis for processing
- transparency and notice
- data minimisation
- retention limits
- international transfer safeguards
- processor/controller roles
- data subject rights
- human review of material automated outputs
Client-specific GDPR obligations should be documented in the applicable agreement, statement of work, or data processing terms.
10. AI Output Validation & Testing
SturdyCloud implements reasonable validation practices, including:
- testing with representative prompts and use cases
- human review of outputs before use
- iterative improvement of prompts and workflows
- ongoing monitoring of output quality and reliability where support is included
- review of accessibility and usability issues for user-facing workflows
AI outputs are not guaranteed to be accurate or complete.
11. AI Output & Decision-Making Limitations
SturdyCloud does not use AI systems for fully automated:
- legal decisions
- financial or investment decisions
- employment or hiring decisions
- medical or health-related decisions
- other material decisions without human review
All material actions require human review and approval.
AI outputs may be useful for drafting, summarisation, recommendations, and operational support, but they are not a substitute for professional judgment or final human approval.
12. AI Office Extension and Voice/Call Workflows
AI Office Extension and similar voice or call-answering workflows may support:
- tier-1 customer support
- booking and scheduling
- sales and lead qualification
- after-hours inquiry capture
- payment reminder support
- field logistics, dispatch intake, maintenance requests, and post-service feedback
These workflows should include:
- approved scripts or call flows
- escalation rules
- human handoff for sensitive or complex issues
- clear limits on what the AI can decide or promise
- call recording or transcript handling rules where applicable
- client review of workflow configuration
- privacy, consent, and retention practices appropriate to the use case
13. AI Incident Handling
AI-related issues may include:
- harmful or incorrect outputs
- data exposure concerns
- workflow or automation errors
- hallucinated statements
- incorrect customer routing or escalation
- accessibility barriers in AI-enabled interfaces
- inappropriate or non-compliant outreach
When identified, SturdyCloud will:
- review and assess the issue
- contain and mitigate impact where possible
- improve safeguards and workflows
- apply learnings to prevent recurrence
14. Logging & Auditability
Where appropriate, SturdyCloud maintains:
- system and access logs
- workflow activity records
- output and interaction tracking where applicable
- change tracking for prompts or configurations
- records of key approvals, escalations, and handoffs
This supports monitoring, troubleshooting, and accountability.
15. Security & SOC 2 Readiness Alignment
SturdyCloud aligns its practices with SOC 2 Trust Services Criteria:
- Security
- Availability
- Confidentiality
Controls include:
- access management
- encryption where applicable
- monitoring and logging
- incident awareness practices
- controlled vendor and integration review
16. Accessibility & Inclusive Design — WCAG 2.2 AA
AI-enabled systems are designed with accessibility in mind, using WCAG 2.2 AA as the development target where applicable.
We aim to ensure AI-supported interfaces are usable and inclusive for a broad range of users by considering:
- keyboard access
- visible focus states
- readable layouts
- properly labelled forms and controls
- accessible error messages
- sufficient contrast
- text alternatives for meaningful visuals
- captions or transcripts for audio/video where practical
- accessible chat, booking, signing, and support flows
17. Client-Specific Requirements
Where a client agreement, statement of work, or regulatory requirement imposes stricter obligations:
- those requirements take precedence over this policy
- SturdyCloud adapts controls to meet client-specific needs where agreed
- requirements should be documented before implementation
18. Continuous Improvement
We continuously:
- monitor AI system performance
- improve prompts, workflows, and safeguards
- refine accuracy, usability, accessibility, and reliability
- update policies as services, laws, and client needs evolve
19. Changes to This Policy
This policy may be updated periodically.
Updates will be reflected with a revised "Last Updated" date.
The effective date of this policy remains April 2, 2026. The July 6, 2026 update reflects CASL, GDPR-aware, WCAG 2.2, AI, automation, and service-delivery clarifications.
20. Contact Information
SturdyCloud IT Ltd.
Email: contact@sturdyiq.ca
Website: https://sturdyiq.ca
Location: Ontario, Canada
