Data Governance Policy

Version 1.0

1. Purpose and Scope

PURPOSE:

This policy governs the management, protection, and use of GENIE AI’s data assets to:

Improve data quality to enhance AI model performance and business insights.
Ensure compliance with Canadian data protection laws, including:
- The Personal Information Protection and Electronic Documents Act (PIPEDA)
- Applicable provincial privacy laws (e.g., Quebec’s Act to modernize legislative provisions as regards the protection of personal information – Bill 64)
- Canadian Anti-Spam Legislation (CASL) for commercial electronic messages
Mitigate operational, reputational, and security risks.
Support trust and transparency with customers, employees, and partners.

SCOPE:

This policy applies to:

All Personal Information as defined under PIPEDA (“information about an identifiable individual”) stored in production and backup systems.
All training and inference datasets containing or derived from Personal Information.
All employee and contractor data collected and processed in the course of employment.
Any data transferred across provincial or national borders.

Exclusions:

Fully anonymized datasets confirmed by the Data Governance Council to be irreversibly de-identified (as per PIPEDA guidance).
Publicly available data with no restrictions on use.
Personal devices not connected to corporate systems.

Connection to Business Impact:

Non-compliance exposes GENIE AI to regulatory fines up to $10 million (Quebec Bill 64) or $100,000 per violation (PIPEDA).
CASL violations can lead to administrative monetary penalties up to $10 million per violation.
Data misuse or breaches create significant brand and trust risks in the AI sector.

2. Roles and Responsibilities

ROLES INCLUDE:

Data Governance Council
- Strategic oversight, policy approval, and ensuring alignment with Canadian and international regulations.
- Quarterly compliance reviews.
Chief Data Officer (CDO)
- Overall accountability for privacy, security, and governance compliance.
- Coordinates Data Privacy Impact Assessments (DPIAs) as required under Bill 64.
Domain Data Stewards
- Day-to-day management of data quality and access.
- Ensure appropriate consent management and purpose limitation for data use.
Data Custodians
- Technical enforcement of security safeguards mandated by PIPEDA (e.g., encryption, access controls).
- Maintain audit trails of access and processing activities.
Data Users
- Use data in compliance with this policy, PIPEDA, and CASL requirements.
- Complete privacy and security training.

Lifecycle Role Mapping:

Data Lifecycle Stage	Responsible Role
New Source Approval	Steward + CDO + Legal Counsel
Consent Management	Steward + CDO
Data Ingestion & Labeling	Custodians
Quality Monitoring	Stewards
Access Provisioning	Custodians + Stewards
Model Training	Data Users
Cross-Border Transfers	CDO + Legal Counsel
Data Archival/Destruction	Custodians + Stewards

3. Data Standards and Definitions

BUSINESS GLOSSARY (WITH LEGAL DEFINITIONS)

Personal Information (PIPEDA): Information about an identifiable individual, including contact details, financial records, and unique identifiers.
Consent: Voluntary agreement to collect, use, or disclose personal information for specific purposes, as per PIPEDA and Bill 64.
Active Customer: Individual who has interacted or transacted with GENIE AI within 90 days.
Training Data: Datasets used to build or refine ML models, subject to purpose limitation and consent verification.

QUALITY THRESHOLDS:

98% completeness of mandatory fields for Personal Information.
Data classified accurately within 48 hours of ingestion.

CLASSIFICATION SCHEMA:

Level	Description
Public	No restrictions
Internal	Internal use only
Confidential	Personal Information (PIPEDA-defined)
Restricted	Sensitive Personal Information (e.g., health, biometric data)

NAMING CONVENTIONS:

Datasets: Domain_Object_Version
Fields: snake_case

MASTER DATA HIERARCHIES:

Customer Master: Salesforce CRM
Product Master: ERP System
Employee Master: HRIS

4. Procedures and Workflows

CONSENT AND PURPOSE SPECIFICATION:

Consent must be obtained in clear, plain language before data collection.
Any new use requires fresh consent if inconsistent with the original purpose.

CROSS-BORDER DATA TRANSFERS:

All cross-border transfers must ensure “substantially similar” protection as required by PIPEDA.
CDO must approve any transfer of Personal Information outside Canada.
Individuals must be informed if their data will be stored or processed abroad.

DATA ACCESS REQUESTS (PIPEDA ACCESS RIGHTS):

Individuals may request access to their data.
Requests responded to within 30 calendar days.
Processed by Stewards and reviewed by the CDO.

DATA CORRECTION REQUESTS:

Requests for correction responded to within 30 calendar days.

NEW DATASET ONBOARDING:

Privacy Impact Assessment required if dataset includes Personal Information.
Security measures (e.g., encryption) documented prior to approval.

DATA BREACH NOTIFICATION:

Breaches involving Personal Information must be reported to the Privacy Commissioner of Canada and affected individuals “as soon as feasible.”

DATA RETENTION AND DESCRTUCTION:

Data retained only as long as necessary for identified purposes.
Secure destruction confirmed and logged.

EXCEPTION HANDLING:

Documented rationale and Council approval required.

5. Compliance and Enforcement

AUTOMATED MONITORING:

Real-time checks for policy violations and unauthorized access.

AUDIT SCHEDULE:

Quarterly internal audits of compliance with PIPEDA and applicable provincial laws.
Annual external audit and certification review.

TRAINING REQUIREMENTS:

Mandatory privacy training for all employees on Canadian laws.
Annual refresher training.

VIOLATION CONSEQUENCES:

1st Violation: Written warning and retraining.
2nd Violation: Suspension of access rights.
3rd Violation: Possible termination and regulatory notification.

SUCCESS METRICS:

100% completion of mandatory training.
<1% incidents of policy non-compliance.
100% fulfillment of data access and correction requests within timelines.

6. Supporting Policies

Data Privacy Policy (PIPEDA, Bill 64)
Data Quality Policy
Data Security Policy
Data Lifecycle Policy
Data Ethics Policy
Data Definitions and Models

7. Legal References

This policy aligns with:

PIPEDA (S.C. 2000, c. 5)
Quebec Act respecting the protection of personal information in the private sector (as amended by Bill 64)
Canadian Anti-Spam Legislation (CASL)
Applicable provincial legislation

APPROVED BY:
GENIE AI Data Governance Council

EFFECTIVE DATE:
July 16, 2025

Data Governance Policy

Company

Solutions

Legal

Head Office

Property+

Project+

Health+

Retail+