Data handling & compliance posture

The vendor review, answered up front.

Somewhere between the assessment and the build, your IT lead or your counsel is going to ask who my subprocessors are, where the data sits, how long I keep it, and what happens when we're done. Those answers are on this page rather than three weeks into a questionnaire. Where the honest answer is "I don't do that," it says so.

ENGINEERING PRACTICE · NOT A LEGAL WARRANTY reviewed and dated below

The posture

Built to the strictest standard, everywhere.

Privacy law in the United States is a patchwork. Nineteen-plus states have comprehensive privacy statutes, they don't agree with each other, and new ones arrive every session. Chasing that with a fifty-state matrix produces a document that's out of date the week it's published.

So I don't build to the local minimum. Systems I build are designed to the strictest common denominator: California-level privacy practice, data minimization by default, and disclosure wherever a person is interacting with an AI, regardless of which state your company or your customers sit in. A company operating only in Texas gets the same handling as one selling into California, because your customer list usually crosses state lines whether or not your offices do, and because building two standards means eventually applying the wrong one.

That's a design commitment about how I build, not a certification. I'm a one-person engineering practice, not a compliance department, which cuts both ways. There's no offshore team and no staff turnover to manage in your access review, and there's also no SOC 2 report to hand you. Everything below is written to be independently checkable rather than taken on faith.

What actually gets stored

The data inventory.

What an engagement actually touches, across the assessment, the build, and ongoing operations. Engagement-specific data is scoped in writing before anything connects. This is the baseline.

DataWhy it existsWhere it livesRetention
Assessment material interview notes, process maps The raw input to your findings and roadmap report My workstation, encrypted full-disk encryption Deleted 90 days after report delivery manual, calendar-tracked, not automated
Business documents invoices, tickets, contracts, forms The material the automation reads and processes Your systems wherever the architecture allows client-controlled by default Per engagement scope, in writing
Extracted records structured output of a pipeline The deliverable: what gets written into your system of record Your systems of record Yours, governed by your retention policy, not mine
Verification logs claims, checks, verdicts, timestamps The audit trail behind every monthly accuracy report Engagement infrastructure, US region 13 months scheduled purge, verified
Operational telemetry volumes, error rates, latency Monitoring and degradation alerting Engagement infrastructure, US region 13 months scheduled purge, verified
Credentials & access API keys, service accounts Connecting your systems to the automation Secret manager, never in code, documents, or chat Revoked by you at engagement end
Inquiry form submissions this website Responding to you before an engagement exists Supabase, US region 24 months scheduled purge, verified
Prospect & contact records business contact details, notes, published research Knowing who I've spoken to and what was said: the sales pipeline Supabase, US region No fixed clock deleted on request, or when the record goes cold. See below

Never stored, in any engagement: payment card numbers · Social Security numbers · bank credentials · government ID numbers · protected health information · biometric identifiers. Where a document pipeline would otherwise encounter one of these, the field is redacted before storage or the document is routed to a human instead. Payments run through Stripe and card data never reaches my systems.

Who else touches it

The subprocessor list, in public.

Every AI system is a chain of vendors, and your review will need the list. Here's the baseline: what each one sees, and where their terms live so your counsel can read them without asking me first.

ProviderRoleWhat it seesTerms
SupabaseDatabase of recordVerification logs, telemetry, inquiry submissionsprivacy
VercelWeb & API hostingRequest metadata, form submissions in transitprivacy
AnthropicLanguage modelConversation and document text at inference timeprivacy
StripePaymentsBilling details. Card data never reaches my systemsprivacy
BoldSignContract signatureThe contract itself, plus signer name, email, IP and timestamps on the completion certificateprivacy
Namecheap Private EmailBusiness emailCorrespondence with you, and any document attached to itprivacy
ResendAutomated email deliveryNotification and digest messages in transit, including names and contact details submitted through the contact formprivacy

All primary storage is US-region. This is the baseline stack. Your engagement gets its own subprocessor list, because the integrations that matter are yours: your ERP, your CRM, your ticketing system, your document store. That list is written into the engagement documentation before anything connects, and no subprocessor is ever added to a live client system without telling you first. Where your policy rules out a vendor on this list, say so during the assessment. Most of the stack is substitutable if it's known early, and considerably more expensive to swap after the build.

The controls, specifically

What's actually implemented.

Not aspirations. These are in the running systems today, and they're the same practices the reliability standard is built on. A control nobody verifies isn't a control.

Access

Who can reach what

  • Credentials held in environment secrets, never in source code or documents
  • Scheduled jobs authenticate with a bearer token, so there are no unauthenticated triggers
  • Record lookups validate identifier format before touching the database
  • Rate limiting on operational endpoints
  • Single operator, so no staff, contractors, or offshore team with access to your data, and no access review to run when someone leaves

Input handling

Hostile-input assumptions

  • Every external input is untrusted by default: documents, form fields, API responses
  • Output escaped before rendering, so no HTML injection through a form field
  • Prompt-injection guards wherever a model reads untrusted content
  • An AI's self-reported success is never accepted as proof it worked
  • Confidence floors, so the system declines and routes to a human rather than guessing

Transport & storage

Data in motion and at rest

  • TLS on every connection, no exceptions
  • Encryption at rest via the storage platform
  • Test data flagged and separated from production records at the schema level
  • No personal data placed in URLs or query strings
  • Retention windows enforced by a nightly purge that re-reads the data after deleting and reports if anything survived
  • Every run of that purge is recorded: start, finish, rows removed, and whether the re-read came back clean. A purge that stops running is itself a silent failure, so the job that enforces the windows is monitored like anything else I build

Checking my own work

I audit myself, and I write down what I find.

The section above lists controls. This one is how I check they are still true, because the same standard I apply to a system I build for you has to survive being pointed at my own.

Every sweep, four buckets

What gets written down

A full pass over my own repository and infrastructure: secrets exposure, injection surfaces, authentication, prompt injection. Every finding lands in one of four categories, and all four are recorded, not just the flattering ones:

  • Fixed: the issue, and the deploy that closed it
  • Verified clean: what was checked and passed, so a future sweep knows what was already covered
  • Accepted risk: deliberate, with the reason and the condition that would change the decision
  • Outside what this audit can see: named explicitly rather than left implied

The last two carry the weight. A security review with no accepted risks is one where nobody looked hard, and a review that doesn't name its own blind spots is claiming omniscience.

What you get, and what you don't

The findings stay private

I won't publish the audit itself. A live, itemized list of a running system's weaknesses isn't transparency. It's a target list, and any vendor who hands you one is telling you something about their judgment.

What you get instead is concrete: a written answer to your security questionnaire, a walkthrough of the current posture with your security team, and the subprocessor and dependency lists for your engagement. That is on the record in the data processing agreement, not just on this page.

One thing I will say about the last sweep: it produced fixes, not a clean bill of health. A self-audit that finds nothing is a self-audit that wasn't really performed, and I'd rather tell you that than claim a perfect score.

AI-specific practice

Disclosure, consent, and the human in the loop.

The rules that apply specifically because there's an AI involved. Several of which are becoming law and most of which should have been table stakes anyway.

Disclosure

People are told

Where a system I build interacts directly with a person, whether that is your customer, your vendor, or your own staff, they're told they're dealing with an AI, in plain language, at the start. No pretending to be a person, no ambiguous naming designed to blur the line.

This is increasingly a legal requirement rather than a courtesy, and it's cheaper to build in than to retrofit when your state's disclosure law takes effect. Internal-only automation that processes documents without interacting with a person doesn't need this, and I won't pretend otherwise to pad a compliance story.

Human oversight

What AI doesn't decide

Systems I build don't make consequential decisions about people. No automated screening or ranking of applicants or employees. No creditworthiness or eligibility scoring. No automated denial of service to anyone. If a prospective engagement requires it, that's a scope I decline rather than one I improvise.

Where an AI system produces an output that affects a person, a human reviews it before it takes effect. Low-confidence outputs route to a person by design, not by exception.

Training

Your data isn't a product

Client data is not used to train models, is not sold, is not shared with other clients, and is not used to build anything I market to someone else. Model providers are used under commercial terms that exclude training on submitted content.

Outbound contact

Contact rules

Automated outbound contact, meaning customer notifications, collections follow-up and renewal outreach, is built against do-not-call and anti-spam requirements: accurate sender identification, honored unsubscribes, and consent tracking where marketing contact is involved. AI-generated voice on an outbound call carries additional federal restrictions, and that constraint goes in the design, not the disclaimer.

If a proposed system's economics depend on ignoring those rules, that's a finding in the assessment rather than a surprise after the invoice.

Intellectual property

Who owns the code, and can it infringe?

You own the deliverable on full payment, and my terms indemnify you against claims that my work product infringes someone else's IP. That is only worth something if I can actually keep it, so license review is a gate on the build, not a formality. It runs before the acceptance session, and the dependency list ships with your handoff documentation.

License familyDoes it ship in your deliverable?
Permissive MIT, BSD, Apache-2.0, ISC Yes. Attribution notices required by the license are carried into your handoff documentation.
Copyleft GPL, AGPL, SSPL Not without your written agreement. If one is genuinely the right tool, you are told in writing what it obligates you to before it goes anywhere near the build, and it is named in the SOW or a change order.
Unlicensed or unknown no license file, unclear provenance Never. It does not ship at all.

Every third-party package, model, dataset and template embedded in or required by the deliverable is inventoried by name, version and license, generated from the lockfile where one exists, written down by hand where one doesn't. That list goes in your repository and your handoff pack, so a question two years from now has an answer rather than an archaeology project.

The question everyone is now asking

AI-generated code

A meaningful amount of what I write is drafted with an LLM. Pretending otherwise would be absurd from a practice that sells AI systems, so here is the actual standard.

Generated code is reviewed and materially modified before delivery, and never committed unread. It is treated as mine to indemnify, to exactly the same standard as code I typed character by character. The provenance of the draft does not change who answers for the result.

What I don't touch

Your code stays yours

Anything you hand me, whether source, data, documents or templates, remains yours, and the rights and consents in it remain your responsibility. I don't relicense it, don't redistribute it, and don't fold it into anything I build for anyone else.

The reusable methods and tooling I bring to an engagement stay mine, and you get a license to use them in what I deliver. That split is written in the terms rather than left to be discovered at exit.

The honest limit. This is a review by one engineer against the license text and the lockfile. It is not a legal clearance opinion and not a patent search, and I won't describe it as one. It catches what actually bites in practice: copyleft creeping into a deliverable, an unlicensed snippet, a missing attribution notice. If your risk profile needs formal IP clearance, that is outside counsel's job and it should be budgeted as such.

Your data, your call

Deletion, export, and exit.

ON REQUEST What you can demand

  • A complete export of everything stored about you or your customers, in a usable format
  • A written answer to your security questionnaire, and I'd rather fill out yours than insist you accept this page
  • Deletion of any record or of everything, with written confirmation of what was removed
  • Deletion requests passed through to subprocessors where their terms allow
  • The full subprocessor list for your specific engagement, including integrations
  • Everything handed over at the end of an engagement: systems, prompts, data, documentation

NEVER What doesn't happen

  • Your data held hostage to keep you on a retainer
  • Data retained past the stated window because deleting it was inconvenient
  • Client data sold, brokered, or used to train anything
  • A new subprocessor added to your live system without telling you
  • A breach handled quietly. You're notified, in writing, with what's known and what isn't

How to exercise any of this

One address, no ticket system

Email byron@walkeraisystems.com with what you want. Deletion and export requests are acknowledged within two business days and completed within thirty days. You get written confirmation of what was actually removed, not a promise that it was handled. Every deletion is verified by re-querying the same records afterwards, because a database's own success report is a self-report, and the confirmation names what was kept too, with the reason.

A data processing agreement already exists. Ask and it comes back the same day, with the processing details, security measures, and your engagement's subprocessor list filled in rather than left as a blank annex. Send yours instead if you'd rather; I'll read it. Same address for security questionnaires and anything else your counsel needs before an engagement starts.

The governing agreements are published in full rather than summarized here: the Terms of Service, covering ownership, the guarantee, liability and indemnity, and the Privacy Policy. Every Statement of Work is written against them, and a dated copy of the Terms as they stood that day is sent in the same envelope as the SOW, so there is never a question about which version you agreed to.

Make a data request

By industry

The rules that apply to your field.

What I design around depending on your sector. Find yours, and if the constraint that matters most to you isn't listed, that's a good question to open the assessment with.

Manufacturing & distribution most common

Usually the lightest regulatory load and the heaviest integration debt, which is where the actual risk lives.

  • Trade secrets and pricing. Your BOMs, margins, supplier terms, and customer pricing are the crown jewels. These stay in your systems wherever the architecture allows, and they are never used to train anything or inform another client's work.
  • Supplier and customer contracts. Many carry confidentiality terms that flow down to your vendors. I'll want to know what those obligate before a pipeline reads them.
  • Export controls. If your technical data is ITAR or EAR controlled, say so first, because it constrains which model providers and hosting regions are usable, and that decision has to be made before the build, not during.
  • OT and plant systems. Anything touching production floor systems is scoped read-only unless there's a specific, deliberate reason otherwise.
Financial services safeguards rule

The federal definition of "financial institution" reaches well past banks: lenders, mortgage brokers, insurance agencies, advisors, collection agencies, and auto dealers are frequently covered. That brings a written information security program requirement that flows down to service providers like me.

  • Engagements here get the security program documented in the engagement agreement before any system goes live
  • Account numbers, routing details, and credentials are never stored
  • Automated lending, underwriting, or eligibility decisions are outside my scope, because the model-governance and adverse-action burden belongs with a vendor built for it
  • Books-and-records retention obligations may exceed my default windows; yours govern, and they go in the engagement documentation

Say so early. It changes the shape of the engagement and it's far cheaper to design for than to retrofit.

Energy services critical infrastructure

Back-office and field-operations automation is well within scope. Control systems are not.

  • Nothing touches OT, SCADA, or control systems. Ticketing, invoicing, compliance reporting, field data, and scheduling: yes. Anything with a physical actuator on the other end: no.
  • Regulatory reporting. Where automation produces a filing or a compliance record, the verification trail is the deliverable, and a human signs off before anything is submitted.
  • Landowner and royalty data. Personal data under state privacy law, handled as such.
Professional firms: legal, accounting, engineering confidentiality

Confidentiality obligations here are usually stricter than any privacy statute, and they're yours to satisfy. My job is not to create a problem for them.

  • Privileged material handled under whatever your professional obligations require, documented in the engagement agreement
  • Conflict-of-interest walls respected. I'll disclose if I'm engaged with an adverse party, and decline where it matters
  • Client-controlled storage strongly preferred; several firms require the data never leave their tenancy, and that's a workable constraint if it's known up front
  • Your own client-notification obligations around AI use may apply, so it is worth checking against your bar or professional body before the build
Healthcare administration limited scope

I do not currently sign business associate agreements and I do not handle protected health information. That's a deliberate limit, stated plainly. A one-person practice without a formal compliance program has no business claiming otherwise, and a vendor who'd sign that BAA without hesitating is telling you something.

Administrative work that never touches patient data can still be in scope: vendor invoicing, supply chain, credentialing logistics, internal reporting. That gets scoped carefully and in writing, with the boundary made explicit, or it doesn't happen.

If the project needs PHI, the honest answer is to hire someone else, and I'll say so in the first conversation rather than the third.

Any company with employees applies broadly

Regardless of sector, automation that touches hiring, performance, scheduling, or termination sits in the fastest-moving area of AI regulation right now. Several states and cities now require bias audits or disclosure for automated employment decision tools.

  • I don't build automated screening, ranking, or scoring of applicants or employees
  • Automation that supports HR workflow, meaning routing, document handling and scheduling logistics, is in scope, with the decision staying with a person
  • Where the line is unclear, it gets drawn explicitly in the engagement scope rather than left to interpretation

Backed by

Insurance in force.

Two policies, both current, both written in the name of Walker AI Systems LLC. A certificate naming your company as certificate holder is available on request, usually the same day you ask.

01 · Professional liability

Errors & omissions

$1,000,000 per claim and $1,000,000 aggregate, written by Philadelphia Indemnity Insurance Company (A.M. Best A++, Superior). This is the one that matters here: it responds when the work product itself causes a financial loss, which is the failure mode a systems engagement actually has.

02 · General liability

Commercial general liability

$1,000,000 each occurrence and $2,000,000 aggregate, including $1,000,000 personal and advertising injury, written by The Hartford (A.M. Best A+, Superior).

Both policies run 27 July 2026 through 27 July 2027. Additional insured and waiver of subrogation endorsements are available where your vendor agreement requires them. Ask before signing, not after.

The honest part

What I don't do, and what I'm not claiming.

A compliance page that only lists strengths isn't a compliance page, it's marketing. Here's the other half.

Out of scope · not negotiable

  • No SOC 2 certification. The controls above map to recognized security frameworks, but no auditor has verified them. I describe what's implemented; I don't claim a certification I don't hold.
  • No HIPAA business associate agreements. No protected health information, in any engagement.
  • No payment card data. Card processing stays with your processor. My systems never see a card number.
  • No biometric identification. No voiceprints, no facial recognition, no biometric identifiers derived from your staff or your customers.
  • No consequential automated decisions. Nothing that automatically decides housing, employment, credit, insurance, or access to a service.
  • No legal advice. I'm an engineer. This page describes how I build. It is not a legal opinion about your obligations, and it isn't a substitute for your own counsel.

If your project needs something on this list, the right answer is a vendor who's built for it, and I'd rather tell you that in the first conversation than discover it in month three.

When something goes wrong

Incident handling.

01 · Detect

Independent verification

Systems verify their own work against the source of truth rather than trusting self-reports. Drift and schema changes are monitored, not assumed away. The reliability page demonstrates the mechanism, and the receipts show what its absence has cost others.

02 · Notify

You hear it from me

If data you're responsible for is exposed, you're notified in writing without delay, with what's known, what isn't yet known, and what's being done. No waiting until the picture is flattering.

03 · Report

Written postmortem

Cause, scope, timeline, and the change that prevents recurrence. On operate-and-maintain engagements it lands in the monthly report whether or not you noticed the incident.

04 · Before any of that

The plan is written down, and you can read it before you sign.

Incident response here is a document, not an intention: version 2.0, dated 27 July 2026, reviewed annually and after any incident. It defines what counts as an incident and at what severity. It fixes the order of the first hour, starting with the instruction not to wipe the machine, because repairing the evidence destroys any ability to prove how far the problem did or didn't reach. It orders credential rotation by dependency rather than by panic, with domain and email first, since that is what an attacker uses to reset everything else, with an explicit check for the silent mail-forwarding rule that survives a password change.

It also specifies what evidence is preserved before anything is fixed, what you are told, how fast, and the section most plans leave out entirely: what this practice cannot do on its own at two in the morning.

Ask and I'll email it to you. Most vendors will tell you they have an incident response plan. The useful follow-up question is whether they'll send it to you before you've signed anything.

The pitch, plainly

Ask your current AI vendor for this page.

Ask who their subprocessors are, where your documents are processed, how long they retain what they extract, and what happens to all of it if you cancel. If that answer takes three weeks and arrives from an account manager, you've learned something. Every assessment I run asks those same questions about the systems you already have running.

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$2,500 fixed scope · two-week turnaround · if you don't need me, that goes in the report