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9.6 Use, Procurement, and Development of Generative Artificial Intelligence
This online version is for convenience; the official version of this policy is housed in the University Secretariat. In case of discrepancy between the online version and the official version held by the Secretariat, the official version shall prevail.
Approving Authority: President
Original Approval Date: May 13, 2025
Date of Most Recent Review/Revision: N/A
Office of Accountability: Provost and Vice-President: Academic
Administrative Responsibility: Associate Vice-President: Academic and Chief Information Officer
1.00 Purpose
1.01 The purpose of this policy is to establish guidelines to ensure that all Members of the University Community use GenAI tools responsibly, ethically, and in compliance with applicable regulations and University policies.
2.00 Definitions
2.01 Generative Artificial Intelligence (GenAI): A category of artificial intelligence tools that generate new outputs, similar in characteristic to the data on which they have been trained, in the form of images, text, audio, and more.
2.02 Generative Artificial Intelligence Impact Assessment (GAIA): A process used to identify and mitigate risks associated with the use of GenAI technology. A GAIA is used to conduct a thorough assessment of the proposed technology and to apply due diligence in protecting the University’s content generation, decision-making, and intellectual property and copyright obligations.
2.03 Member(s) of the University Community: Persons who currently live, work, or study (in person or online) on any Laurier campus. Members include students (including student groups), employees, adjunct and visiting faculty, and volunteers at Laurier.
2.04 Classes of Information:
2.04.01 Open Information (Type 1): Information that is readily available to any Member of the University Community or to the general public, either by request or by virtue of being posted or published by the university through proper administrative procedures. This type of information has no restrictions on access or usage. It may include Personal Information collected for the express purpose of public release with the knowledge and consent of the individuals the information is about, or records created for public circulation.
2.04.02 Internal Information (Type 2): Information whose unauthorized release could reasonably be expected to cause minor, short-term harm to individuals or to the University and is intended for only limited dissemination. Internal Information must be guarded due to proprietary, ethical, or privacy considerations, and must be protected from unauthorized access, modification, distribution, storage or other use. Protection of such information may be required by university policy and/or provincial or federal legislation. Access to Internal Information is restricted to those who have a legitimate purpose for accessing such information. It is important to note that internal information in the aggregate may migrate to Restricted Information, particularly with respect to Personal Information about an individual.
2.04.03 Restricted Information (Type 3): Information that, if compromised, could reasonably be expected to result in significant and/or lasting harm to an individual or the University such as identity theft or reputational risk. This type of information is strictly protected by provincial or federal statutes or regulations, University policy, or contractual agreement(s) and must be protected from unauthorized access, modification, distribution, storage, destruction, or use. Access to Restricted Information is limited to those who have a legitimate purpose for accessing such information.
3.00 Jurisdiction/Scope
3.01 This policy governs the use, procurement, and/or development of standalone GenAI tools and tools that utilize or embed GenAI by a Member of the University Community, or persons or companies contracted by the University, for the conduct of university business and affairs.
4.00 Policy
4.01 The University cannot abrogate its responsibility for content generated and decisions made, and the impact of those decisions on students, faculty, and staff, to GenAI. Any content generated and/or decisions informed, influenced, or made by GenAI technology for the purposes of University business or affairs must be reviewed by the user of the GenAI technology. The Members of the University Community who use GenAI technology retain full responsibility for all content and decisions, and this accountability cannot be assigned to any automated system used in the decision-making process.
4.02 Use of GenAI Technology
4.02.01 Members of the University Community who use GenAI technology hold responsibility, within all reasonable efforts, for the accuracy of the inputs, content generated, and decisions made.
4.02.02 Members of the University Community who use GenAI technology must ensure that the content generated and the decisions that are made comply with human rights and accessibility obligations and do not include or amplify biases.
4.02.03 The use of GenAI technology for content generation and/or decision-making must be clearly acknowledged.
4.02.04 Any GenAI technology that is used with Type 2 or Type 3 information must be approved through Policy 9.5 External Information Technology and Cloud Services and the PSIA-approval process.
4.02.05 Members of the University Community who use GenAI technology must take all reasonable steps to ensure that the submitted input and generated content does not violate third-party intellectual property rights.
4.02.06 Any use of GenAI technology must comply with all applicable Laurier policies, including Policy 9.1 Use of Information Technology.
4.02.07 Any use of GenAI technology must comply with all applicable legislation.
4.02.08 Content generated by a GenAI technology for university business or affairs is considered information and must be handled in accordance with all applicable Laurier policies, including Policy 10.1 Privacy Protection and Information Access and Policy 10.4 Information Governance.
4.03 Procurement, Acquisition, and/or Development of GenAI Technology
4.03.01 Whenever standalone GenAI tools and/or tools that embed GenAI are being considered for procurement (or acquiring for free), use and/or development at Laurier, the following provisions shall apply.
a. Any contract or agreement entered into with a third party to provide GenAI technology to Laurier, and/or any GenAI technology developed internally at Laurier, must conform with applicable laws and all applicable Laurier policies, including Policy 9.1 Use of Information Technology, Policy 9.4 Information Security Policy Statement, Policy 9.5 External Information Technology and Cloud Services, and Policy 5.7 Signing Authority.
b. A GAIA must be completed as part of an assessment of the risks of the use of GenAI for content generation and decision-making. In the event that the GAIA identifies risk, the Chief Information Officer, the Provost and Vice President Academic, and the University Counsel and Chief Legal Officer (or their designates) will review the identified risks and determine if mitigation strategies are available to allow the technology to be used in a way that meets the University’s risk threshold for use. Approval of the technology also includes implementation of all required risk mitigation strategies.
4.04 Use of Unapproved GenAI Technology
4.04.01 Members of the University Community may use unapproved GenAI technology for the conduct of University business and affairs with Open Information (Type 1) for content generation purposes only. Such use comes with the expectation that 4.02 above is adhered to and without any expectation of assistance or technical support from ICT or any designate, unless explicitly agreed to by both parties via a Service Level Agreement (“SLA”) or similar contract.
4.04.02 Users are responsible to ensure that only Open Information (Type 1) is used. Changes to use that include Internal (Type 2) or Restricted (Type 3) Information will require GAIA review.
Relevant Legislation
- O. Reg. 476/24 Rules and Exemptions Re. Job Postings (ontario.ca), effective January 2026