How to document AI compliance for CPCSC

Canadian federal organizations deploying AI systems must maintain comprehensive documentation under Communications Security Establishment's Canadian Centre for Cyber Security (CPCSC) guidelines. This documentation serves dual purposes: demonstrating regulatory compliance and enabling rapid incident response. The Treasury Board Directive on Automated Decision-Making (sections 6.1.1-6.3.2) requires detailed impact assessments, while CPCSC ITSG-33 cyber security frameworks demand ongoing monitoring records and audit trails.

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Core documentation requirements

CPCSC expects federal organizations to maintain four categories of AI compliance documentation. Each category addresses specific regulatory requirements under Treasury Board Directive on Automated Decision-Making sections 6.1-6.3 and related cyber security frameworks per ITSG-33 guidance.

Impact Assessment Documentation forms the foundation under Treasury Board Directive section 6.1.1. Organizations must document algorithmic impact assessments before system deployment, including risk ratings per Appendix C criteria, bias evaluations under section 6.1.3, and human oversight protocols meeting section 6.2.1 requirements. High-impact systems (Level 3-4) require enhanced documentation under section 6.2.8.

Technical Architecture Records detail system components, data flows, and security controls per ITSG-33 AC-4 requirements. CPCSC guidelines require network diagrams showing AI system integration points, data residency confirmations under Privacy Act section 8, and third-party service dependencies documented per Treasury Board Directive section 6.3.3.

"Federal AI systems must maintain complete data lineage documentation under Privacy Act section 4, from initial training data through production outputs, with particular attention to cross-border data flows prohibited under section 8(2) without lawful authority. CPCSC ITSG-33 requires documented approval for any transborder data processing."

Operational Monitoring Logs capture ongoing system performance and security events per ITSG-33 AU-6 requirements. Organizations must document model accuracy metrics against Treasury Board Directive Appendix C thresholds, bias detection results under section 6.2.2, and any unusual system behavior. CPCSC frameworks require real-time monitoring capabilities with automated alerting for anomalous activity under SI-4 controls.

Incident Response Documentation records any AI system failures, security breaches, or compliance violations per Treasury Board Directive section 6.3.1. Federal organizations must maintain detailed incident timelines, remediation actions within 30 days, and lessons learned documentation meeting ITSG-33 IR-4 requirements.

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Data residency and sovereignty documentation

CPCSC places particular emphasis on documenting data residency and sovereignty controls for AI systems under Privacy Act section 8 and ITSG-33 SC-7 boundary protection requirements. Federal organizations must maintain clear records of where AI processing occurs and which jurisdictions have potential data access.

Geographic Processing Records must identify the physical location of all AI computation per Privacy Act section 8(2) requirements, including training, inference, and data storage. Organizations must document any cloud service providers, their jurisdictional presence, and applicable foreign access laws like the US CLOUD Act that could conflict with Privacy Act protections.

Privacy Act section 8 requires federal institutions to protect personal information from foreign disclosure except under specific subsection 8(2) authorities. AI systems processing personal information must document compliance with these restrictions and any authorized disclosures with Treasury Board approval under section 8(2)(e).

Vendor Assessment Documentation becomes critical when using third-party AI services under Treasury Board Directive section 6.3.3. Organizations must document due diligence assessments, contractual privacy protections meeting Privacy Act standards, and ongoing compliance monitoring for external providers per PIPEDA Principle 7 where commercial relationships exist.

"CPCSC ITSG-33 SC-7 requires federal organizations to maintain detailed vendor assessments for any AI service provider, with particular scrutiny of foreign ownership structures and potential government access requirements that could violate Privacy Act section 8 protections. Canadian-sovereign platforms eliminate these compliance documentation burdens."

Augure addresses these requirements through its sovereign architecture, maintaining all AI processing within Canadian borders without US corporate parents or foreign access obligations. Organizations using Augure's Canadian infrastructure can document simplified data residency compliance under Privacy Act section 8.

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Audit trail requirements

Federal AI systems must maintain comprehensive audit trails enabling regulatory review and incident investigation per ITSG-33 AU-2 through AU-12 controls. CPCSC frameworks require these trails to support both operational oversight and Treasury Board Directive compliance verification.

Decision Audit Logs must capture sufficient detail to reconstruct AI-driven decisions affecting individuals under Treasury Board Directive section 6.2.3. Organizations must document explanation capabilities meeting section 6.2.4 requirements and demonstrate human oversight implementation per section 6.2.1 standards.

Model Performance Documentation tracks AI system accuracy against Treasury Board Directive Appendix C impact thresholds, bias metrics under section 6.2.2, and performance degradation requiring system review per section 6.2.8. Organizations must document regular model validation procedures and corrective actions when performance falls below established thresholds within 30 days per section 6.3.1.

Access Control Records document who accessed AI systems per ITSG-33 AC-2 requirements, when access occurred, and what actions were performed. CPCSC cyber security frameworks require detailed logging of administrative access, model updates, and configuration changes meeting AU-3 audit content standards.

Data Handling Logs track personal information processing through AI systems under Privacy Act section 4 collection requirements. Organizations must document data collection purposes, processing activities, retention periods per Treasury Board Personal Information Bank standards, and deletion procedures under Privacy Act section 12(2).

"Effective AI audit trails must be tamper-evident per ITSG-33 AU-9 requirements, regularly backed up under CP-9 standards, and accessible to authorized reviewers within 24 hours of Privacy Commissioner or Treasury Board Secretariat compliance requests under respective audit authorities."

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Integration with existing compliance frameworks

AI compliance documentation must integrate with broader federal compliance programs including Privacy Act obligations, PIPEDA requirements for commercial activities under federal jurisdiction, cyber security incident reporting per CPCSC guidelines, and Treasury Board Management Accountability Framework reporting.

Privacy Impact Assessment Integration requires organizations to update existing PIAs when deploying AI systems processing personal information under Treasury Board PIA Policy requirements. Privacy Commissioner guidance expects detailed AI-specific privacy risk assessments addressing automated decision-making impacts as part of standard PIA documentation.

Cyber Security Event Reporting under CPCSC ITSG-33 IR-6 requirements must include AI-related incidents. Organizations must document how AI system compromises are detected, reported within prescribed timeframes, and remediated meeting Treasury Board cyber security event management standards.

Management Accountability Framework reporting may require AI-specific metrics and compliance indicators under Treasury Board Secretariat expectations. Organizations should align AI documentation with existing performance measurement and risk management processes meeting MAF core management areas.

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Quebec-specific considerations

Federal organizations operating AI systems affecting Quebec residents must address Law 25 requirements even within federal jurisdiction, particularly for commercial activities or shared provincial-federal programs.

Cross-Jurisdictional Documentation must address Law 25 section 93 Privacy Impact Assessment requirements for AI systems processing personal information of Quebec residents. Organizations must document compliance with both Privacy Act federal requirements and Law 25 provincial standards where applicable.

Consent and Transparency Documentation must meet Law 25 sections 14-16 consent requirements and sections 8-13 transparency obligations where Quebec residents are affected. Federal organizations must document how AI systems comply with Law 25's enhanced consent standards, even when Privacy Act provides different federal authorities.

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Practical documentation templates

Federal organizations benefit from standardized documentation templates addressing common CPCSC requirements and Treasury Board Directive obligations. These templates ensure consistent compliance documentation across departments and agencies.

AI System Profile Template should include system purpose, technical architecture per ITSG-33 documentation standards, data sources meeting Privacy Act collection requirements, decision logic addressing Treasury Board Directive section 6.2.4, human oversight procedures per section 6.2.1, and performance metrics against Appendix C thresholds. Organizations must update these profiles whenever system components change per section 6.3.1.

Monthly Compliance Reports can summarize AI system performance against Treasury Board thresholds, compliance incidents under section 6.3.1, and remediation activities. Regular reporting demonstrates ongoing oversight under section 6.2.8 and helps identify systemic compliance issues requiring Treasury Board Secretariat notification.

Vendor Assessment Checklist should address data residency per Privacy Act section 8, foreign ownership structures, government access requirements conflicting with Canadian law, security controls meeting ITSG-33 standards, and compliance certifications. Organizations must reassess vendors annually or when contractual terms change per Treasury Board contracting policies.

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Documentation retention and access

CPCSC guidelines require federal organizations to maintain AI compliance documentation for specific retention periods under Treasury Board Information Management Policy and ensure authorized access for regulatory review by Privacy Commissioner, Treasury Board Secretariat, and departmental audit functions.

Retention Requirements follow Treasury Board Directive on Recordkeeping standards: seven-year retention for impact assessments and compliance reports, with audit logs maintained per ITSG-33 AU-11 requirements (typically 1-3 years depending on system classification). Organizations must maintain documentation in accessible formats throughout retention periods.

Access Controls must balance compliance transparency with operational security per ITSG-33 AC-3 requirements. Documentation systems should support role-based access with comprehensive audit logging of reviewer activities meeting AU-2 audit standards.

Federal organizations can establish compliant AI documentation programs by implementing systematic record-keeping meeting Treasury Board and CPCSC standards, regular compliance reviews per regulatory timelines, and clear escalation procedures for compliance violations. Organizations seeking simplified compliance documentation can explore Augure's Canadian-sovereign AI platform at augureai.ca, which eliminates foreign data residency concerns while maintaining full Canadian regulatory compliance.