Before staff use AI with client information, leadership needs a clear decision about which data can enter which tools, who reviews outputs, and what happens when a customer requests access or deletion.
The Office of the Privacy Commissioner of Canada advises businesses to limit sensitive and confidential information sharing, build safeguards into AI use, and be transparent about how information is used.
A practical first step is to approve one workflow with a defined data boundary and review step. This gives teams useful guidance without
Client information can appear in ordinary work more often than leaders expect. A support request may include a name, contact detail, contract number, location, family detail, or a note about a service issue. The question is not whether AI is useful. The question is whether that information belongs in the tool the team has chosen.slowing every AI use into a policy exercise.
Start by separating information that can be used from information that needs a different path. Public material may be suitable for research or drafting. Client records, financial information, employee information, and confidential project details need an approved decision before they are entered into an AI tool.
The review step matters just as much as the data boundary. Someone needs to own the result before it is sent to a client, used to make a recommendation, or saved back into a business system. AI can prepare work. People remain accountable for the decision.
Teams also need a clear response when a client asks about their information. The business should know which tool was used, what information was shared, what retention terms apply, and who can respond to an access or deletion request.
This is why the first approved workflow should be narrow. It gives the team a useful rule they can follow and gives leadership a practical way to improve it as the business learns.
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