Generative Artificial Intelligence (GenAI) Policy

Seneca is committed to leveraging available technologies to work smarter, better and more efficiently. This includes the use of Generative Artificial Intelligence (GenAI) technologies. While encouraging Seneca employees to continually seek new and improved ways to implement these technologies, it is necessary to do so in a way that ensures the safety of our systems, compliance with regulations, and ethical standards of practices. Given the rapid advances of GenAI technologies and tools, this policy serves as a general framework to ensure responsible and safe use of GenAI in academic and operational contexts.

This policy applies to students, employees, and other contracted third parties’ use of GenAI applications or development of GenAI models, including internal models, third-party models or publicly available applications such as ChatGPT and other similar applications that mimic human intelligence to generate answers, work product or perform certain tasks. 

This policy also applies to the use of those applications on Seneca devices and/or personal devices when used for any Seneca work or study purposes.

Artificial intelligence technology that synthesizes new versions of text, audio, or visual imagery from bodies of data in response to user prompts. GenAI models can be used in stand-alone applications, such as ChatGPT, or incorporated into other tools such as internet search engines or word processing applications.

The sole right to produce, reproduce and copy a work. In Canada, all original creative works are automatically protected by copyright upon their creation, and protection applies whether or not a copyright symbol appears on the material. Only the copyright owner or its authorized licensees have the right to decide when and how the work is to be copied, altered or made available. Regardless of format, the use, reproduction, and distribution of copyright protected materials are subject to limits and restrictions.

Any form of knowledge or expression created by one's intellect that can be legally protected, including technical information, inventions, models, drawings, photographs, specifications, prototypes, computer software and other creations that can be protected under patent, copyright, trademark, integrated circuit topography, plant breeders rights and/or industrial design laws. For the purposes of this policy, confidential information having a commercial value is also to be considered Intellectual Property.

Approved GenAI applications include any software licenses, subscriptions, or tools where ITS and/or Teaching & Learning were consulted in the decision to allow use. An assessment of the vendor’s privacy and security practices, how GenAI is incorporated, and how it works, would have been completed for such applications.

Unapproved GenAI applications include software licenses, subscriptions or tools acquired without consulting ITS and/or Teaching & Learning and without completing a privacy and security assessment.

Any information that Seneca would not want publicly disclosed including, but not limited to, proprietary, commercial, technical, financial, or employment related information, as well as student and employee personal information.

1. GenAI tools could provide fictitious answers, sometimes referred to as hallucinations.  Users must review output from GenAI tools for accuracy to avoid placing Seneca at risk or harming institutional reputation.
2. GenAI tools may incorporate inherent biases of the data sets that were used to train them that may not always align with Seneca’s core values and or the institutional commitments to reconciliation, equity, diversity inclusion and sustainability.
3. GenAI outputs can include systematic errors or favour certain groups, leading to unfair or discriminatory outcomes.  Where GenAI is used to make decisions or provide analysis of information that may be subject to bias, outputs should be regularly reviewed by the employees/department using the tool to assess bias risk.
4. To protect students, employees and partners from harm, and to protect Seneca from reputational damage, students, employees and contractors must use GenAI pursuant to Seneca’s Respectful Workplace Policy and, and Information Technology Acceptable User policy, as well as other related Seneca policies as they apply.
5. GenAI-created content that is inappropriate, discriminatory, or otherwise harmful must not be used for Seneca work or study purposes.

1. GenAI outputs can contain copyrighted information or others’ intellectual property. While ownership in many of these cases is unclear, students, employees and contractors should refrain from using any GenAI output that contains material (either internal or external) believed to be under copyright protection.
2. To ensure transparency with students, employees and contractors and protect Seneca from claims against copyright infringement and/or theft of intellectual property, all GenAI generated content must be reviewed by the individual using the GenAI, and declaration of use and/or citation included when being used for work purposes.

1. GenAI usage must be in accordance with this policy to mitigate the risk of sensitive and confidential information being leaked and/or misrepresented through unapproved GenAI applications. Any such unintended disclosures pose risk of violation of Seneca’s contractual obligations with business partners and/or legal parameters.

1. When using or developing GenAI content or tools, all students, employees and contractors are expected to:
   • comply with applicable laws, regulations, and related Seneca policies.
   • reference output that was used for work or academic purposes to the GenAI application that created it through a label, footnote or other means visible to the reader, viewer or listener.
   • maintain a record of when GenAI has been used to produce content for work purposes (beyond basic administrative tasks) and be prepared to share records with their supervisor, professor, or other authorized personnel upon request.
   • review output of GenAI applications to make sure it meets Seneca’s ethical standards and principles of reconciliation, equity, diversity, inclusion and sustainability.

1. It is a violation of Seneca’s policy to:
   • use Seneca credentials to log into publicly available GenAI applications.
   • install unapproved Application Programming Interfaces (APIs), plug-ins, connectors or software related to GenAI systems.
   • use outputs generated from unauthorized GenAI applications for work purposes, conducted on behalf of Seneca (e.g., implementing code that has been generated by an unapproved GenAI into a Seneca system).
   • enter content that contains Seneca’s or third parties’ intellectual property and copyrighted materials into unapproved GenAI applications.
   • enter personal information about students, employees, or third parties into unapproved GenAI applications.
   • input de-identified personal information into unapproved GenAI applications to seek responses that are then used to make decisions about a specific individual or group.
   • use outputs that discriminate against individuals based on a protected ground under the Ontario Human Rights Code and the Respectful Workplace Policy.
   • use GenAI applications to create text, audio or visual content for purposes of committing fraud or to misrepresent an individual’s or group’s identity.
   • use Gen AI in a manner that does not comply with Seneca policies.

1. Students and employees who fail to comply with any provision of this policy may be subject to discipline.
2. Violations by contractors may be considered a breach of contract and result in removal from assignment and/or termination of the contract.
3. Any GenAI-related activities which appear to violate criminal or civil laws may be reported to law enforcement agencies.

• Academic Integrity Policy
• Conflict of Interest Policy
• Copyright Policy
• Ethical Conduct for Research Involving Human Subjects Policy
• Fair Dealing for Copyright-Protected Work Policy
• Free Speech Policy
• Freedom of Information and Protection of Privacy Policy
• Information Technology Acceptable Use Policy
• Intellectual Property Policy
• Personal Safety/Security Threats Policy
• Recording Lectures and Educational Activities Policy
• Respectful Workplace Policy
• Responsible Conduct of Research Policy
• Student Code of Conduct
• Sexual Violence Policy
• Social Media Policy

• Canadian Charter of Rights and Freedoms
• Copyright Act R.S.C,. 1985, c. C-42
• Criminal Code R.S.C,. 1985, c. C-46
• Human Rights Code, R.S.O. 1990, c. H. 19
• Occupational Health and Safety Act, R.S.O. 1990, c. O.1
• Accessibility for Ontarians with Disabilities Act, 2005, S.O. 2005, c. 11
• Canada’s Anti-Spam Legislation
• Freedom of Information and Protection of Privacy Act, R.S.O. 1990, c. F.31
• Personal Health Information Protection Act, 2004, S.O. 2004, c. 3, Sched. A

Approval Date: March 2024