AI & Data Processing Policy

Clearstep's AI Principle

Clearstep uses AI where it helps, not everywhere. Some workflows need better software, clearer records, stronger handoffs, dashboards, portals, integrations, or human review before they need AI. When AI is useful, it should be limited, purposeful, reviewable, and connected to real business value.

AI Tools May Be Used for Software and Service Work

Clearstep may use AI tools for software development, code generation, debugging, code review, architecture planning, workflow analysis, documentation, summaries, internal notes, drafting emails or proposals, data extraction, classification, routing, interface copy, business logic, research, support triage, and issue investigation.

AI assistance does not replace human judgment. Clearstep remains responsible for reviewing work before delivery according to the project scope.

AI Providers and Consumer Tools

Clearstep may use tools from OpenAI, Anthropic, Google, and other providers. Provider availability, names, features, and terms may change over time.

Clearstep may use both consumer and business/API AI tools for software development, debugging, drafting, workflow review, documentation, and internal project support.

Clearstep will not intentionally submit sensitive, confidential, regulated, or client-identifying data to consumer AI tools unless the client has specifically consented in writing and the use is appropriate for the project.

For sensitive client data, Clearstep will prefer redaction, summarization, synthetic examples, or business/API tools with stronger administrative, privacy, and data-control options where available.

Sensitive Data and Consent

Clearstep will not intentionally submit sensitive client data to AI providers unless all of the following are true. Sensitive data may include customer records, contracts, pricing and margin information, employee information, payroll records, tax records, bank or payment information, legal records, healthcare information, protected health information, photos, child or minor data, internal notes, credentials, or confidential business files.

1. The client has provided written consent.
2. The purpose is connected to the project.
3. The data is reasonably necessary for that purpose.
4. The provider and workflow are appropriate for the sensitivity of the information.

Consent may be recorded in a statement of work, written email approval, AI consent form, portal consent record, or other written project approval.

Redaction, Minimization, and Regulated Data

When AI assistance is useful but sensitive information is not needed, Clearstep will use reasonable efforts to redact, summarize, anonymize, or remove sensitive details before using AI tools. Clients should avoid sending unnecessary sensitive information.

Clearstep does not accept regulated, highly sensitive, healthcare/PHI, legal case, tax, payroll, financial-account, government-ID, or child/minor data unless Clearstep has specifically agreed in writing through a project-specific scope and any required addendum.

Clearstep does not agree to act as a HIPAA business associate, legal-service provider, tax adviser, financial adviser, payroll processor, or regulated compliance provider unless a separate written agreement says so.

Human Review

AI outputs may be inaccurate, incomplete, outdated, biased, non-unique, or unsuitable for a specific business context. Important outputs should be reviewed by a human before use.

• Customer-facing messages.
• Pricing, quote, billing, or margin decisions.
• Legal, medical, tax, financial, employment, or regulated interpretations.
• Business-critical workflow rules.
• Code that affects security, payments, access control, or data privacy.
• Outputs involving sensitive client or customer information.

Client Responsibilities

• Provide accurate information.
• Have the right to share all data provided to Clearstep.
• Identify regulated, sensitive, or restricted data.
• Obtain required permissions from customers, employees, users, vendors, or other parties.
• Review outputs, workflows, business rules, and deliverables for the client's own operational and legal requirements.
• Tell Clearstep if certain data may not be used with AI tools.

Records, Ownership, Provider Terms, and Changes

For projects involving sensitive AI processing, Clearstep should document consent and the basic purpose of the AI use. Where the portal or admin system supports it, Clearstep may keep structured records such as consent records or AI run logs showing provider, purpose, project, data type, consent status, timestamp, and responsible user.

Clearstep may use AI tools to help create code, documentation, tests, diagrams, and other project materials. Unless otherwise stated in the statement of work, the client owns the final custom deliverables created specifically for the client after full payment, subject to Clearstep's retained rights in pre-existing materials, reusable components, frameworks, templates, know-how, generalized methods, and third-party/open-source materials.

AI providers have their own terms, policies, privacy practices, data-processing terms, and limitations. Clearstep's use of AI tools is also subject to those provider terms. Clearstep may update this Policy from time to time as tools, provider terms, and legal requirements change.

Contact

Clearstep Systems is a service brand operated by Pshichenko Enterprises Inc. Email: legal@clearstepsystems.com.