This policy states how artificial intelligence is used in the WorkpaperIQ service, what governs that use, and what control your firm has over it. It is written for the people who have to answer for it inside your firm — the engagement partner, the quality-management lead, and the vendor-risk reviewer — and it is meant to be readable end to end in about ten minutes.
| Applies to | The WorkpaperIQ workpaper-review service and the InspectionIQ pre-issuance risk tool |
|---|---|
| Owner | Sibo Zhu (Engineering), with Frank (Professional standards) and Ricki (Operations) |
| Version | v1.0 — 2026-09-03 |
| Review cadence | At least annually, and after any material incident or architecture change |
How to read this document. We describe in the present tense only what is true today. Anything planned but not yet operating appears in the Roadmap at the end, with an owner and a date wherever one is set — never in the body. Where a common industry claim does not yet apply to us, we say so plainly rather than omitting the question.
WorkpaperIQ reads a package of completed audit workpapers and produces advisory review comments: observations, questions, suggested actions, and references, each anchored to a specific file, tab, and — where determinable — cell.
It performs no audit, attest, or assurance service. It renders no professional opinion or conclusion. Every output is an input to a qualified professional's judgment on your engagement team, and nothing it produces is audit evidence.
Position statement. Your engagement team performs the audit. The product raises candidates for your attention; the decision on every one of them is yours, is recorded as yours, and is signed by a named person on your team.
It matters for risk assessment that not everything in the service is a language model. Reading a spreadsheet, resolving merged cells, extracting formulas, matching a citation against the uploaded file list, enforcing a severity downgrade, deleting a file after a run — these are deterministic code paths that behave identically every time. Language models are used for classification, for the review reasoning itself, for a second-pass review, and for the adversarial re-check described in §5.
We call third-party large language models through inference APIs only. We operate no model of our own, and we do not fine-tune or otherwise train models.
| Provider | Used for | Sees workpaper content |
|---|---|---|
| Enterprise LLM inference endpoint (our primary review engine; provider and contracting entity named to your reviewer on request) | Primary review reasoning, second-pass review, scoring | Yes — workpaper excerpts inside prompts |
| Anthropic (Claude API) | Parts of the analysis, the in-product help assistant, and internal quality scoring | Yes — workpaper excerpts inside prompts |
| DeepSeek API | Internal development experimentation only | No. Barred by policy from production customer data and restricted to synthetic and internal test material. Client analyses are technically pinned to the production engine; a technical enforcement review covering every path is Roadmap R2 |
Every model provider is approved under our Vendor & Subprocessor Management Policy and listed in the subprocessor register we provide to your reviewer on request. The provider and contracting entity behind the primary endpoint are named to your vendor-risk reviewer on request. That policy sets a minimum of 30 days' advance notice before a new material subprocessor processes customer data; the commitment takes effect with our first production Order Form.
The in-product help assistant is deliberately narrower than the review engine: it sees interface state only — which screen you are on, how many findings there are, which filters are active, how much credit remains, and the names you gave the session and its files — and never the contents of your workpapers or findings. Each question is relayed through our server to the model provider to be answered; we do not store the conversation, except that if you rate an answer we keep that question and answer to improve the assistant.
The application and all customer data are hosted on AWS. Production runs today in ap-northeast-2 (Seoul). Migration to a U.S. region (us-east) is a committed Roadmap item (R3), and the residency commitment takes effect as stated in your Order Form; where U.S. residency is a precondition for your firm, tell us and it becomes a gating item on your onboarding rather than a footnote.
Residency describes where we host your data. Workpaper excerpts are additionally transmitted to our model providers' inference APIs for processing, in the regions those providers operate; the residency commitment covers our hosting, and the providers' processing terms are covered in §4.
All public endpoints serve traffic over TLS, so data is encrypted in transit. Encryption at rest on our storage volumes is not yet verified; verifying and, if needed, enabling it is Roadmap R6. Multi-factor authentication on our infrastructure accounts is Roadmap R7. We would rather a reviewer read those two sentences here than discover them in a questionnaire.
| Data | Retention |
|---|---|
| Uploaded source files | Deleted from the server immediately after the analysis run completes |
| Analysis results and the organisation-scoped archived copy of the workpapers | Life of the engagement plus 60 days after termination, or earlier on a deletion request |
| Operational logs | Rotated; credential-shaped values (access codes, tokens, sign-in links) are stripped before logs are written, and email addresses are masked wherever logs, reports and dashboards display them |
| Personal trial-tier usage records (which days an analysis ran, technical signals, the spend ledger) | Deleted automatically after 90 days; the account record itself is kept until the account is deleted |
The working copy of each upload is deleted when the run finishes. A copy of the submitted file is kept in your firm's archive alongside the results, so a re-run or a fix-verification does not require a fresh upload; that archive is purged on request. This is our starter retention schedule — a complete written schedule covering every store is Roadmap R8.
Every session, engagement binder, and credit pool is scoped to one firm, enforced server-side. Within a firm, engagement runs carry an entity gate at the classification stage, before any review work: on the first run the service records the audited-entity names it reads in your package and binds the engagement to them, and those names are shown on the engagement's scope line; on later runs, a package that names a different entity is stopped and a human is asked to approve, rather than letting one client's workpapers enter another client's binder. The gate needs a recognisable entity name to act on — a package of unlabelled scans or schedules will not trigger it — and it applies to engagement runs, not to stand-alone sessions.
One engineering administrator can open customer sessions, and only for support, debugging, and operations. Operational logs, reports, and dashboards display masked email addresses and masked access codes. Access codes are issued per firm and per role; a preparer seat can be configured to see only the sessions it created.
We do not train or fine-tune any model on customer data. We build no datasets from it. Your workpapers, findings, and engagement data are never used in prompt development or in benchmarking — our benchmark sets are purpose-built fictional workpaper packages with deliberately planted deficiencies.
Nor do our model providers. Both production providers are used through inference APIs under enterprise terms that commit them not to train on the data we send. Your workpaper content is processed to answer the request and is not retained as training data.
What we can put in front of a reviewer. We hold no-training, inference-only commitments from each production provider and will make the confirmations available to your vendor-risk reviewer on request, alongside our subprocessor register.
Every control in this section is a mechanism in the software, not a policy aspiration:
Every analysis reports its own coverage: which files and which tabs were actually read, which were read only in part and to what row, which were not read and why, and which could not be opened at all. A finding that stands on a file the service could not read is collapsed into one "could not be read" card for that file and routed for manual review — it is never presented as a missing workpaper.
WorkpaperIQ is an AI product end to end, so "use the service without AI" is not a meaningful option. What your firm does control is what the AI ever sees, on which engagements, and for how long:
| Control | How it works |
|---|---|
| Which engagements | You decide which engagements and which audit areas are run through the service at all. There is no automatic ingestion of anything. |
| Which files | Selection is per file, and the tick list is shown before the run starts. You can untick anything, the run reads only what is ticked, and the coverage record shows exactly what was read. |
| Which entities | An engagement is bound to the audited-entity names recorded on its first run. To add a name, you file a scope request from the blocked-run page and our team approves it; the request and the approval are recorded, and recorded names are not removed. A later package naming a different entity is stopped for human approval before any review work. |
| Who in your firm | Access codes are issued per role (preparer, reviewer). Preparer seats can be scoped so a preparer sees only their own sessions. |
| Deletion | On request, we purge a session's retained workpapers, results, and outputs. Binder removals follow a signed, audited removal process that records who removed what and when. |
| Client-specific restrictions | If one of your audit clients restricts or prohibits AI use on its engagement, tell us and we will document it at the engagement level; the practical implementation is that the engagement is not run through the service, or is run only on the parts the restriction allows. |
If your own client's terms restrict AI, those terms control. We will not ask you to reconcile a conflict between this policy and an obligation you owe your client — tell us the constraint and we will document and honour it.
Any change to a model, a prompt, or the review logic must pass a benchmark regression before it reaches production. The change is run against our landmine benchmark sets — fictional workpaper packages with known planted deficiencies — and scored by an automated judge against the prior baseline. Detection of critical planted deficiencies must hold — a change that reduces it does not ship. A movement outside our tolerance band on lower-severity measures is escalated and can be released only on documented approval, with the deviation recorded in the release note.
New features reach a data-isolated development environment first, and production deployments happen only in a window with no active customer analysis running. Each release is recorded with what changed, the benchmark result, and the rollback path.
These items are known and owned, and dated wherever a date is set. Until an item ships, we describe it exactly as it appears here and nowhere else.
| # | Item | Target | Owner |
|---|---|---|---|
| R1 | File the countersigned no-training / inference-only confirmations from each production provider in the vendor register (terms secured; originals in transit) | 2026-09-12 | Sibo |
| R2 | Enforcement review of the development-model picker, confirming development-only models cannot receive production customer data | 2026-09-15 | Sibo |
| R3 | Production migration to a U.S. region, with a data-residency commitment in the engagement documents | Before the first paid production engagement; takes effect as stated in each Order Form | Sibo |
| R4 | Benchmark methodology documented in a form shareable under NDA for vendor-risk reviews | 2026-10-15 | To be assigned |
| R5 | Applicability review of the Texas Responsible AI Governance Act with counsel | 2026-09-30 | Ricki |
| R6 | Verify, and if needed enable, encryption at rest on production storage volumes | 2026-09-15 | Sibo |
| R7 | Multi-factor authentication on infrastructure accounts | 2026-09-15 | Sibo |
| R8 | Complete written retention schedule covering every data store | Date to be set | Sibo & Ricki |
Vendor-risk questionnaires, security reviews, and questions from your own audit clients are welcome, and we would rather answer them in detail than in summary. Our companion AI: Client Questions & Answers document covers the questions we are asked most often, including the ones your audit clients are likely to ask you.