Substance Law assists businesses, platforms, agencies, professionals, and regulated organizations with drafting, reviewing, and implementing AI disclosure policies across Canada. As artificial intelligence tools become increasingly integrated into business operations, marketing, customer service, professional work, content creation, and regulated industries, organizations face growing legal, reputational, and compliance risks relating to AI transparency.
An AI disclosure policy can help organizations explain when and how artificial intelligence is used, manage stakeholder expectations, reduce misleading representations, support privacy compliance, and address industry-specific regulatory concerns.
We assist clients with practical AI disclosure policies tailored to their operations, technology, customers, and legal risk profile.
What Is an AI Disclosure Policy?
An AI disclosure policy is a written policy explaining how an organization uses artificial intelligence tools and when AI-generated or AI-assisted outputs are disclosed to users, customers, employees, clients, regulators, or the public.
AI disclosure policies may address:
- AI-generated content
- AI-assisted professional work
- chatbot interactions
- automated decision-making
- AI use in marketing
- AI use in customer service
- human review and oversight
- data inputs and privacy considerations
The appropriate policy depends on the organization’s industry, business model, and risk profile.
Why AI Disclosure Policies Matter
AI disclosure policies can help businesses:
- improve transparency
- reduce misleading communications
- manage customer expectations
- support privacy and data governance
- address regulatory expectations
- reduce reputational risk
- clarify when human review is used
As AI tools become more common, businesses should ensure their use of AI is not misleading, unfair, or inconsistent with privacy and consumer protection obligations.
AI Disclosure Policies for Websites and Platforms
Businesses using AI on websites, mobile applications, or online platforms may require user-facing disclosures.
We assist with policies relating to:
- AI chatbots
- automated customer support
- AI-generated recommendations
- AI-assisted content
- online decision tools
- user-facing AI features
Disclosure language should be clear, accurate, and consistent with how the technology actually operates.
AI Disclosure for Marketing and Advertising
AI-generated marketing content may create legal risk if consumers are misled about authenticity, endorsements, claims, or source.
We assist with disclosure policies relating to:
- AI-generated ads
- synthetic images and videos
- influencer content
- product descriptions
- testimonials and reviews
- social media posts
- promotional campaigns
AI advertising disclosures should be assessed alongside general advertising, competition, and consumer protection laws.
AI Use in Professional Services
Professional service firms using AI tools may need policies governing how AI is used in client work.
We assist with policies addressing:
- AI-assisted research
- document drafting
- client communications
- professional supervision
- confidentiality
- human review
- limitations of AI-generated outputs
Professional organizations should ensure AI use aligns with confidentiality, competence, supervision, and client disclosure obligations.
AI Disclosure and Privacy Compliance
AI systems often process personal information, customer data, employee data, or confidential business information.
We assist with:
- privacy disclosures for AI tools
- data collection and use notices
- AI vendor review
- cross-border data transfer considerations
- consent language
- data retention practices
AI disclosure policies should often be coordinated with privacy policies and internal data governance practices.
AI Disclosure and Automated Decision-Making
Businesses using AI for decisions affecting individuals may face heightened transparency expectations.
This may include AI use in:
- hiring and recruitment
- credit or risk assessment
- fraud screening
- customer eligibility
- pricing or personalization
- moderation decisions
Organizations should assess whether users should be informed about automated or AI-assisted decision-making and whether human review procedures are appropriate.
Internal AI Use Policies
In addition to public-facing AI disclosures, many organizations require internal AI policies for employees and contractors.
We assist with internal policies addressing:
- approved AI tools
- prohibited uses
- confidential information restrictions
- client data handling
- review requirements
- accountability and supervision
- recordkeeping
Internal AI policies can help prevent accidental disclosure of confidential or personal information.
AI Vendor and Third-Party Risk
Many organizations use third-party AI vendors.
We assist with:
- AI vendor contract reviews
- data processing terms
- confidentiality provisions
- intellectual property ownership
- output use rights
- liability allocation
- security and privacy obligations
Vendor arrangements should be reviewed carefully before deploying AI tools in business operations.
AI-Generated Content and Intellectual Property
AI-generated content may raise ownership, licensing, and infringement issues.
We advise on:
- ownership of AI-generated outputs
- use of third-party training data concerns
- copyright risks
- brand and trademark risks
- content review procedures
- commercial use of AI-generated materials
Organizations should implement policies to manage intellectual property risks associated with AI tools.
AI Disclosure in Regulated Industries
Certain industries may require heightened caution when using AI.
We assist businesses operating in:
- healthcare and wellness
- cannabis and controlled substances
- food and beverage
- cosmetics and natural health products
- fintech and payments
- e-commerce
- professional services
Regulated industries should ensure AI-generated claims, recommendations, or outputs do not create compliance issues.
AI Policy Reviews and Gap Assessments
We assist organizations with reviewing existing AI practices and policies.
This may include:
- AI use audits
- disclosure gap assessments
- website and platform reviews
- internal policy reviews
- privacy and vendor risk assessments
- marketing compliance reviews
A practical review can help identify areas where disclosure, oversight, or policy controls may be needed.
Why Work With Substance Law
- experience with regulated businesses and digital platforms
- practical privacy, advertising, and technology compliance guidance
- business-focused AI policy drafting
- support for both internal and external AI disclosures
- experience across consumer products, fintech, healthcare, cannabis, and e-commerce
We assist organizations in creating AI disclosure policies that are clear, accurate, and operationally realistic.
Work With an AI Disclosure Policy Lawyer in Canada
If your organization uses artificial intelligence tools in customer interactions, marketing, professional services, internal operations, or regulated business activities, an AI disclosure policy may help reduce legal and reputational risk.
Substance Law provides AI disclosure policy drafting, review, and compliance services across Canada.
Contact Substance Law to discuss your AI disclosure policy needs.
Frequently Asked Questions About AI Disclosure Policies
What is an AI disclosure policy?
An AI disclosure policy is a written policy explaining when and how an organization uses artificial intelligence and when AI-generated or AI-assisted outputs are disclosed to users, customers, employees, clients, or the public.
Do businesses need to disclose AI use in Canada?
Disclosure requirements depend on the context, industry, and use case. Businesses should avoid misleading users and may need disclosures where AI affects customer interactions, content, decision-making, privacy, or regulated services.
When should AI-generated content be disclosed?
AI-generated content may need disclosure where failing to disclose would mislead users, affect trust, create consumer protection concerns, or conflict with platform, professional, or regulatory expectations.
Can AI disclosure policies help with privacy compliance?
Yes. AI disclosure policies can work alongside privacy policies by explaining how AI tools collect, process, or use personal information.
Should companies have internal AI use policies?
Yes. Internal AI policies can help employees understand approved tools, prohibited uses, confidentiality restrictions, human review requirements, and data handling rules.
Can AI tools create intellectual property risks?
Yes. AI-generated outputs may raise copyright, licensing, ownership, and infringement issues depending on the tool, inputs, and intended use.
Do regulated industries need special AI disclosure policies?
Often yes. Businesses in healthcare, fintech, food, cannabis, cosmetics, and other regulated industries should ensure AI use does not create advertising, privacy, professional, or regulatory compliance issues.
Can lawyers draft AI disclosure policies?
Yes. Lawyers can draft AI disclosure policies tailored to a business’s AI tools, operations, industry, privacy obligations, and legal risk profile.
