Privacy
What we collect, where it is held, how long we keep it, and what we do and do not do with it. Every answer is on this page. Open a section for the detail behind it.
- Your operating data stays with you. We hold no account in your systems, hold no credentials, and cannot view, change, export or delete anything in your environment.
- Assessment work runs on our side. A narrow, listed set of your information comes to our own governed Microsoft environment in Canada for an assessment, and is destroyed ninety days after delivery unless you ask otherwise.
- We are never given the names of the people we survey. We receive headcounts by role; your organization hands out the keys. The link between a person and an answer is never created.
- AI plays no role in your assessment. Nothing from an engagement reaches an AI system. We use AI in our own business, and we say exactly how.
- We do not sell, rent or trade anything about you. There is no advertising on this site.
1. If you have visited this site, joined the list, or entered a draw
This part is about you as a visitor. If your organization has engaged us, Part 2 is the one that applies.
▸ What we collect Your name, organization and work email, whatever you write to us, and ordinary server logs. Nothing else.
- Contact and booking forms. Your name, organization, work email, and whatever you choose to write. Bookings run through Microsoft Bookings and collect your name, work email and meeting time.
- The Governance Self-Check. The check itself runs entirely in your browser and sends us nothing. If you ask for a copy of your result by email, we receive your email address and that result, and nothing else.
- The mailing list. Your email address, and your name if you give it. You joined by asking us to send you something — the Booth 73 summary, the handbook, or both.
- Service requests and Working Session intake. If you send us a request or book a Working Session, the form asks for your name, title, organization, work email and phone, and a few details about your organization and what you need. We use them only to respond to you and, if we work together, to plan and deliver the work. We never ask for your staff’s names or email addresses: for a Working Session, you tell us how many people are taking part, and we send you that many private access codes to hand out.
- Prize draw entries. If you entered a CivicShift draw, we hold the entry and the contact details needed to notify a winner.
- Standard technical information. Our website host records ordinary server information — IP address, browser type, pages visited — in the way almost every website does.
▸ The quiz at our trade show booth Your answer carries nothing that identifies you. If you also gave us your email, it is a separate record and we do not join the two.
The quiz records the answer and nothing that identifies who gave it — no name, no employer, no email. If you also gave us your email address at the booth, it is written as a separate record and we do not join the two. When we publish the results, they are published as counts, and no answer is traced to a person or an organization.
Both records are held in a Google Firebase database in the United States, which is named under who else is involved. One honest limit: because both are written as they happen, the order in which they were written is visible to us. We do not use it to connect an answer to a person, and nothing we publish is derived from it — but we would rather say that than claim a separation the technology does not give us.
▸ What we do with it Answer you, send you what you asked for, run a draw we said we would run, follow up about our services. That is the whole list.
We do not sell your information, rent it, trade it, or hand it to anyone for their own marketing. We do not add you to the mailing list because you filled in a contact form. Every email we send has an unsubscribe link, and unsubscribing works immediately.
▸ Where it is held, and for how long The site is hosted by GoDaddy, what you send us lives in our Microsoft 365 environment in Canada, and the mailing list is with MailerLite in the EU. Kept while there is a live reason, removed when there is not.
The website itself, its forms, the entries those forms collect, and its ordinary server logs are hosted by GoDaddy, outside Canada. Each form entry is also sent to us, and everything that reaches us — your message, your details, and any correspondence that follows — is held in CivicShift's Microsoft 365 environment in the Canada region, and so are bookings. The mailing list is held by MailerLite, in the European Union — if you have joined the list, your email address is there as well as with us.
We keep enquiry and Self-Check information while there is a live reason to — an open conversation, or a follow-up you asked for — and remove it when there is not. Request and Working Session intake entries on the website are deleted automatically two years after you send them. Draw entries are kept until the draw is complete and the winner has claimed, and then for as long as we need them to show the draw was run properly. You stay on the mailing list until you leave it.
2. If your organization has engaged us — or you have been asked to take part
▸ What we receive Four categories and no others: engagement documents, headcounts by role, our own interview notes, and survey responses.
| Category | What it is, and why we have it |
|---|---|
| Engagement documents | What your organization chooses to give us for review — organizational charts, policies, procedures, bylaws, terms of reference, existing process or system documentation. What we ask for is fixed in advance, in writing, in the Document Request List in your agreement. |
| Organizational composition | Headcounts by role, level and work area, taken from your current org chart. It exists to size the survey so that responses reflect representation across positions. No names, no email addresses, no employee numbers. Our own tooling refuses to load a list containing people, so this is enforced rather than promised. |
| Interview notes | Our own notes from confidential leadership interviews. We know who we interviewed, because we sat across the table from them — but nothing any of them says is attributed to them in a deliverable. |
| Survey responses | Classified by role, level and work area. No name, no email address, and no identifier that leads back to either. |
Anything beyond these four categories requires a signed amendment to the agreement. We do not quietly widen the list.
Findings trace back to evidence, not to a model. Our method requires three or more distinct interview sources plus at least one document-sourced item before a finding is treated as supported, and findings are classified as confirmed, gap, or unverified perception.
▸ What we never receive No staff list, no employee records, no health information, no resident or citizen data, no payroll, no credentials of any kind.
A staff list of any kind. Employee or applicant records. Individual training or safety records. Health information of any kind. Resident, citizen or client information. Payroll, compensation, discipline or performance records. Financial or banking systems. Credentials of any kind.
If a document reaches us containing personal or sensitive information we did not ask for, we tell you, we do not use it, and we return or destroy it as you direct. Receiving it does not change what we are permitted to hold.
▸ What we do with what you tell us We cannot connect your answer to your name — the link is never created. Your employer cannot ask us for attributed answers, and cannot waive that for you.
If you are an employee being interviewed or surveyed, this is the part written for you.
- We are never given your name, and never your email address. Your organization gives us headcounts by role, level and work area — how many people, in which positions — and nothing about who those people are. Our own tooling refuses to load a list containing people, so this is enforced in software rather than left to good intentions.
- Your employer gives you your key, not us. We generate unique one-time keys against those headcounts. Your employer assigns them at random to people within each role, hands them out, and keeps that assignment list on its own side. Nothing about who received which key ever comes back to us.
- No response is attributed to an individual in any deliverable. Ever. Not in the report, not in a dashboard, not in a debrief.
- Your employer cannot ask us for attributed responses. Our agreements do not permit us to provide them, and your employer cannot waive that on your behalf. Neither can we — we could not produce them if we wanted to.
- Results are reported by group. Any group where fewer than five people answered is withheld from the report entirely, and the report records that it was withheld.
- We can see how many keys in a role group have been used. We cannot see who used them. That count is what tells us the sample is full. Your answer is written carrying your role, your level and your work area — never your name, never your email address, and never a code derived from either. The link between you and your answers is not deleted afterwards; it is never created.
- What you write in your own words is the one thing we cannot anonymise for you. If you name your shift, your department or your supervisor in a comment, those words are yours and we cannot unsay them. We read comments and report them as themes, never quote them in a way that identifies you or anyone you name, and destroy them ninety days after delivery.
▸ The Working Session questionnaire Safe and fast: about ten minutes, and anonymous by design. No names, no IP address, no device, and individual answers are deleted within four months.
If your organization booked an AI & Modernization Working Session, you may be asked to answer a short questionnaire beforehand. Codes are not linked to names, CivicShift never receives names or email addresses, and no one at your organization sees individual answers. Only combined results are shared.
- Your code only confirms you were invited. Your sponsor receives a set of one-time codes, one per person, and hands them out. We never learn who received which code. When you submit, the code is marked used and is not stored with your answers.
- We do not record your name, IP address or device. The questionnaire runs on our website, hosted by GoDaddy outside Canada, rather than in our Microsoft environment, and it is set up so none of those details are kept with your answers.
- Individual answers are deleted automatically within four months. Where we can, we delete a session’s answers sooner: ninety days after its follow-up report. Only combined results are kept for the report.
- What you write in your own words is yours. As with any survey, if you name a person or a department in a comment, those words stay as written. We report comments as themes, never in a way that identifies you or anyone you name.
▸ Live polling at a keynote or workshop Anonymous. The tool records the count, not the voter, and we collect no contact details through it.
If you voted from your phone during a CivicShift session, that vote is anonymous. We collect no contact details through it and we do not use anything from a live session for any purpose other than that session.
▸ Where it is held Our own Microsoft 365 and Dataverse environment, Canada region, Canadian data centres. One person has access.
Assessment engagements run in CivicShift's own governed Microsoft environment — Microsoft 365 and Microsoft Dataverse, provisioned in the Canada region, in Microsoft-operated Canadian data centres. Nothing is installed in your environment and nothing of yours is licensed to us.
Access is limited to Troy Palmer, on CivicShift devices with full-disk encryption, current security updates and multi-factor authentication on every account that touches client information. CivicShift has no employees, contractors or subcontractors.
▸ Who else is involved Five service providers, all named: Microsoft in Canada, and GoDaddy, MailerLite, Anthropic and Google outside Canada. Thirty days' notice before we add a sixth.
- Microsoft — hosting and productivity services, Canada region. This is where everything from an engagement lives.
- GoDaddy — this website and our domain. Hosting is outside Canada. It holds what the site's own forms collect, including the anonymous Working Session questionnaire, and nothing from an assessment engagement.
- MailerLite — our mailing list. Subscriber data is stored in the European Union, in data centres certified to ISO/IEC 27001. They hold your email address and nothing else about you.
- Anthropic — AI drafting tools used in CivicShift's own business. No engagement material and no personal information reaches it. Processing outside Canada.
- Google — the Firebase database behind our trade show quiz and our live session polling. Storage and processing occur in the United States. Nothing from an assessment engagement ever reaches it — client material stays in the Canadian-region Microsoft environment described above.
Only the first of those five touches engagement material. The other four exist for the website, the mailing list, our own drafting, and the trade show. If we add another, we tell clients in writing at least thirty days beforehand, and a client who objects on reasonable grounds can end the affected engagement without penalty.
▸ If someone demands your information We tell you before we disclose anything, unless the law forbids it — and then as soon as it lifts.
If a court, regulator, law enforcement agency or government authority — in Canada or anywhere else — demands information we hold for you, we tell you promptly, and before we disclose anything, unless the law forbids us from telling you. We disclose only what is legally required, and where we lawfully can, we give you the chance to object or to seek a protective order first. If we are barred from telling you, we record the demand and tell you as soon as that bar lifts.
We raise this because four of our five service providers process outside Canada, and because it is a fair question to ask any vendor that does. The one that holds your engagement material — Microsoft, in the Canada region — is not among them.
▸ How long we keep it Ninety days after delivery, then destroyed — unless you ask otherwise. Three narrow exceptions, all listed.
What you share is held in our governed Canadian-region environment under the engagement agreement, used only for the review, and destroyed ninety days after delivery unless you ask otherwise. We confirm destruction in writing on request.
Three things sit outside that. We keep the final report and design documentation as delivered, together with the signed agreement and invoicing records, for as long as our professional and insurance obligations require. We keep the question set exactly as it was put to your people, and the scored results with small groups already withheld — so that a score can still be explained years later, and so a repeat review can be compared with this one rather than guessed against it. Neither holds a name, an email address or anything an individual wrote; the written comments themselves are destroyed with everything else at ninety days. And a legal hold, a regulator's demand or an unresolved incident pauses destruction until it is dealt with.
We are also straight with you about the limit of "destroyed". We delete from live systems and stop using it. We cannot selectively erase data from the platform backups Microsoft maintains, which are overwritten in the ordinary course, and we will not pretend otherwise.
▸ If something goes wrong You hear from us within 24 hours, with a written account as facts are confirmed. You are the notifier; we support you.
If we become aware of an incident affecting your information, we tell you without unreasonable delay and in any event within 24 hours, with a fuller written account as the facts are confirmed. We preserve records, stop any scheduled destruction, and cooperate with your assessment and with any notification you decide to make. You are the notifier to regulators and to affected individuals. We support you; we do not speak for you.
3. Artificial intelligence
This is the part most privacy policies hedge. Ours doesn't need to: AI plays no role in how you are assessed, and nothing from your engagement reaches an AI system. Here is precisely where AI is used, and where it never is.
▸ Where AI is used In CivicShift's own business — never on your engagement.
CivicShift uses AI tools the way any modern firm does: drafting its own templates, marketing material, and generic text that contains no client information. That is the whole list. Performing an assessment — reading your evidence, scoring your answers, writing your findings — is done by a person, on the CivicShift Assessment Platform, without AI.
The tools we use run on a paid plan held by CivicShift, with model training switched off — terms we verify rather than assume, and if they change, this page changes.
▸ The line we hold to Nothing from an engagement enters any AI service. Not documents, not responses, not notes.
No document you provide, no survey response, no interview note, and no draft finding from your engagement is entered into any AI service — whether or not it names an individual.
This is not a practice we could relax quietly: it is a term of the engagement agreement.
▸ The platform underneath Microsoft's built-in AI is kept switched off in the assessment environment.
The assessment environment runs on Microsoft's Canadian-region cloud, and Microsoft builds AI features into that platform — Copilot, AI Builder. In the environment where engagements run, those features are kept disabled. The commitment above holds at the platform level, not just at the keyboard.
▸ If that ever changed AI-assisted work on a specific task would need your separate signature first — and no current service uses it.
The engagement framework contains a dormant mechanism — a separately signed acknowledgement — under which a narrowly defined, client-approved AI use could someday be agreed. No CivicShift service offered today uses it. It exists so that if that day comes, the decision is yours, in writing, in advance — not a policy update you find out about later.
4. If you are a public body
Most of our municipal clients have obligations under Alberta's Access to Information Act and Protection of Privacy Act. Our role is to support those obligations, not to assume them.
▸ Our role, and yours You remain the public body. We help you answer access requests promptly and at no charge, and we never respond to a regulator for you.
- The record we keep of an engagement is designed to support your own record-keeping and reporting obligations.
- If you receive an access request touching information we hold, we help you respond — promptly, and at no charge.
- You remain the public body. We do not respond to regulators on your behalf, and nothing in our agreement transfers a statutory obligation of yours to us.
▸ What we are, under POPA A contracted service provider is treated as an employee of the public body. We are inside your privacy obligations, not outside them.
Under the Protection of Privacy Act, a contracted service provider is treated as an employee of the public body for privacy purposes. In plain terms: when we work for you, we are inside your privacy obligations rather than outside them. We are bound by the same rules you are, through our agreement with you — and you stay accountable for information handled on your behalf. That is how it should be, and our agreement is written to match it.
▸ If you need a privacy impact assessment A workforce-wide survey may require one. We give you the vendor half at no charge; you prepare, approve and file it.
A public body may be required to complete a privacy impact assessment before a new or substantially changed programme, and for some of those it must be submitted to the Information and Privacy Commissioner. A workforce-wide survey may well be one of them — that is your privacy office's call, not ours, and we would rather raise it early than have it surface halfway through a procurement.
If you need one, we give you the vendor half at no charge: what we receive and why, where it is stored, who our subprocessors are, what security applies, how long we keep it, and how it is destroyed. You prepare it, you approve it, and you file it. We just make our part of it easy.
5. Your rights, and how to use them
▸ Which law applies Alberta's PIPA for our own collection, PIPEDA across borders, CASL for email, and POPA and ATIA through our agreement with a public body.
CivicShift is a private Alberta corporation, not a public body. Our own handling of your information is governed by Alberta's Personal Information Protection Act, and by the federal Personal Information Protection and Electronic Documents Act where information crosses a provincial or national border in the course of commercial activity. Our email is governed by Canada's anti-spam legislation. When we work for a public body, that body's obligations under the Protection of Privacy Act and the Access to Information Act reach us through our agreement with them, as Part 4 describes.
▸ Asking us what we hold, correcting it, deleting it Write to us and we deal with it promptly and at no charge. If we cannot delete something, we tell you which and for how long.
You can ask us what we hold about you, ask us to correct it, and ask us to delete it. Write to the address below and we will deal with it promptly and without charge. If we cannot delete something — because a contract, a legal hold or an insurance obligation requires us to keep it — we will tell you which, and for how long.
One thing we cannot do, and you should know why. If you answered a survey, we cannot find your response to show you, correct it or delete it — because nothing connects it to you. That is the same design that protects you, working in the direction that is less convenient. Your organization holds the list of who received which key; we never do.
You can unsubscribe from any email at any time, and it takes effect immediately.
▸ If you are not satisfied with how we handled it Tell us first and give us a chance to fix it. If we cannot, you can complain to the Alberta Commissioner without our permission.
Tell us first and give us a chance to fix it. If we cannot resolve it, you can complain to the Office of the Information and Privacy Commissioner of Alberta, and you do not need our permission to do so.
▸ Changes to this page If what we do changes, this page changes first. Our agreements are written to match this page, not the other way round.
If what we do changes, this page changes first, and the date at the top changes with it. Our client agreements are written to match this page, not the other way round — so if you ever find this page and an agreement saying different things, that is our mistake and we would like to hear about it.
Questions
Any question about this page, or about information we hold, comes to me directly. There is no queue and no ticket.
Troy Palmer, Director
CivicShift AI Business Solutions Inc.
222 Pacific Cres., Fort McMurray, AB T9K 0E6, Canada
troy.palmer@civicshiftai.com · 780-792-7227
