AI GOVERNANCE

Privacy by design for AI agents.

An AI agent reads your data and acts on it. We assess it before launch, or while it runs: what it can reach, what can take control of it, and how you stop it. Then we write it up so your privacy officer can sign.

Where we stand

New systems, a proven discipline.

Privacy assessment is our core practice: 250+ privacy assessments across a decade, including privacy assessments of AI systems such as biometric liveness checks and a generative-AI contact centre. Agents that use tools and take actions are newer, and we say so. Our agent method is written down, versioned and public.

Read the method changelog →
The problem

An agent is not ordinary software.

  • It can be talked into things.

    A document or email it reads can carry hidden instructions.

  • It usually has more access than it needs.

    Broad access is the easy way to build it.

  • Nobody has checked how to stop it.

    Until someone proves the stop works, it is a hope.

What we assess

Five questions, answered with evidence.

Lens

Reach

What we checkEvery tool and connector: what it needs against what it was given; whether it acts with the user's credentials or its builder'sWhat we measure it againstA permission matrix: needed vs granted
Lens

Manipulation

What we checkExposure to prompt injection, including through documents, email and web pages the agent readsWhat we measure it againstOWASP Top 10 for LLM Applications (2025): prompt injection, sensitive information disclosure, excessive agency
Lens

Autonomy

What we checkWhich actions run unattended, where a person approves, and where the agent must re-authenticateWhat we measure it againstYour approval design, tested at user acceptance
Lens

Personal information

What we checkPurpose, collection limits, retention, transfers outside the province or country, notice of automated decisionsWhat we measure it againstPIPEDA; Quebec's private-sector Act (Law 25); Alberta and BC PIPA; FIPPA for Ontario institutions; the federal Directive on Automated Decision-Making
Lens

The stop

What we checkFive stops — identity, policy, runtime, monitoring and a person — and whether you can show each one worksWhat we measure it againstA five-stop evidence table

What we ask you for:

  • an architecture diagram
  • the list of environments, connectors and tools
  • an identity and permission export
  • DLP and sensitivity-label settings
  • the agent's instructions and knowledge sources
  • vendor and data-processing terms
  • sample conversations from testing

All client files are stored in Canada, secured in Microsoft 365.

The stop

Five stops, each one proven.

  1. 01

    Identity

    The agent acts under an identity you control, with only the access it needs.

  2. 02

    Policy

    Data-loss and sensitivity rules block what it must never send.

  3. 03

    Runtime

    You can pause or switch it off while it runs.

  4. 04

    Monitoring

    Its actions are logged, and someone looks.

  5. 05

    A person

    A named person approves the actions that matter.

Ways in

Five ways to work with us.

Your team or your build partner builds the agent. We assess it and give you every control it needs.

  1. 01 · Free

    Agent stop check

    Typical timeline: 15 minutes

    One agent, five questions. You leave with the three things to check first.

    Book it →
  2. 02 · New agents

    Build support

    Typical timeline: 4–8 weeks, alongside your build

    Your developers or build partner build the agent. We assess the build as it goes, from design to go-live, and provide all the controls it needs.

    • Control requirements for your builder
    • Two design sessions
    • Behaviour tests at user acceptance
    • An Agentic Privacy Impact Assessment with a sign-off page
  3. 03 · Live agents

    Agent retrofit

    Typical timeline: 2–4 weeks

    For agents already live. We assess how the agent handles data and what it can do, from both the security-controls and the privacy side, then specify the fixes. Your developers make them; we verify each one.

  4. 04 · After launch

    Ongoing assurance

    A re-check twice a year, and whenever the agent changes.

  5. 05 · Programs

    AI governance for the AI you already run

    Inventory, risk-tier classification and the transparency records your legal team will ask for, mapped to the federal Directive on Automated Decision-Making and, for exporters, the EU AI Act.

    • Directive on Automated Decision-Making and EU AI Act gap mapping
    • Risk-tier classification per system
    • Approval pack ready for sign-off

We never assess what we built. Your developers or your build partner make the fixes; we check them.

The deliverable

One report your reviewer already knows how to read.

The Agentic Privacy Impact Assessment follows the same skeleton as our PIAs, so a privacy office used to PIAs can review it quickly.

  1. 01Executive summary and launch recommendation
  2. 02System description and purpose
  3. 03Data-flow map and data inventory
  4. 04Permission matrix (needed vs granted)
  5. 05Privacy analysis, by principle and by law
  6. 06Agent risk analysis: manipulation, autonomy, the stop
  7. 07Risk register: risk, rating, owner, treatment, status
  8. 08Control requirements and verification status
  9. 09Five-stop evidence table
  10. 10Behaviour test results
  11. 11Residual risk and conditions for launch
  12. 12Sign-off page for your privacy officer
Regulatory map

The rules that already apply to your agent.

Privacy law already applies to what an agent does with personal information. This map shows where to start; it is not legal advice.

If your agent…handles personal information for a private-sector organizationWhat appliesPIPEDA's fair information principles. You stay accountable for personal information you hand to a third party for processing, and must secure comparable protection by contract (Schedule 1, clause 4.1.3). Collection is limited to what the purpose needs (clause 4.4.1). Alberta and British Columbia have their own Personal Information Protection Acts.SourcePIPEDA, laws-lois.justice.gc.ca
If your agent…is a new or overhauled system at an enterprise in QuebecWhat appliesA privacy impact assessment for any project to acquire, develop or overhaul an information system involving personal information (s. 3.3), and before communicating personal information outside Quebec (s. 17).SourceAct respecting the protection of personal information in the private sector (Law 25), legisquebec.gouv.qc.ca
If your agent…makes decisions about people on its own, at an enterprise in QuebecWhat appliesTell the person when a decision is based exclusively on automated processing. On request, explain the information used and the reasons, principal factors and parameters, and let the person submit observations (s. 12.1).SourceSame Act, s. 12.1
If your agent…helps a federal institution make administrative decisionsWhat appliesComplete and publish an Algorithmic Impact Assessment before the system goes into production, and update it when its functionality or scope changes (ss. 6.1.1, 6.1.3).SourceTBS Directive on Automated Decision-Making
If your agent…collects personal information for an Ontario provincial institutionWhat appliesA written assessment before collecting personal information, unless the regulations provide otherwise (s. 38(3)).SourceFIPPA (Ontario), ontario.ca/laws
If your agent…is used by an Ontario public sector entityWhat appliesThe Enhancing Digital Security and Trust Act, 2024 (enacted by Bill 194) sets AI duties (public information, an accountability framework, risk management) for entities the regulations prescribe (s. 5). As of October 2026, no regulation has prescribed them.SourceEDSTA, ontario.ca/laws
If your agent…produces output used in the European UnionWhat appliesThe EU AI Act applies to providers and deployers outside the EU where the AI system's output is used in the Union (Art. 2(1)(c)).SourceRegulation (EU) 2024/1689, eur-lex.europa.eu

Frameworks we map to

  • NIST AI RMF 1.0
  • OWASP Top 10 for LLM Applications (2025)
  • OPC principles for generative AI (2023)

Canada's proposed Artificial Intelligence and Data Act was part of Bill C-27, which died when the parliamentary session ended on January 6, 2025. Sources and the dates we read them are listed on the method changelog.

Who it's for

Built for the people who ship agents, and the people who approve them.

  • AI agencies and builders

    You build agents for clients in regulated sectors. Our independent review answers their privacy and security reviewer before the deal stalls.

  • Organizations running agents

    Health, finance, insurance, legal, HR and the public sector. You need evidence that an agent already in use is safe to keep running.

Three questions we get

We have done privacy assessments of AI systems, including biometric liveness checks and a generative-AI contact centre. Tool-using agents are newer; our agent method builds on 250+ privacy assessments, and its changelog is public.

No, deliberately. We never assess what we built. Your developers or build partner make the fixes, and we verify them.

Build support runs 4–8 weeks alongside your build, so the assessment is ready when the agent is. A retrofit takes 2–4 weeks. A privacy impact assessment or a vendor review takes 1–2 weeks. You get a written scope before we start.

Start the engagement

Start a conversation.

Tell us about the agent. A senior practitioner replies with a scoping call.