Privacy and compliance
Every inspection has you collecting personal information: your clients’ contact details, property addresses and, if you dictate your findings, the voices of people present on someone else’s premises. Law 25 governs that collection and applies to your business, whatever its size.
Lumos builds that framework right into the tool: explicit, timestamped audio capture consent, data you can export at any time, transfers outside Quebec assessed beforehand, and a published privacy policy.
Law 25 modernized Quebec’s Act respecting the protection of personal information in the private sector (CQLR, c. P-39.1). It applies to every enterprise collecting personal information in Quebec, including an inspector working alone. Here are the obligations that touch your practice directly.
Every enterprise must designate a privacy officer (s. 3.1). By default it is the person with the highest authority: in a one-person firm, that is you. Their title and contact information must be published.
Collection is limited to the information necessary for your mandate, and consent must be manifest, free, informed and given for specific purposes. An audio recording captured at a seller’s home falls into that category.
You must inform your clients of the purposes for which you collect their information, then answer their access or rectification requests within 30 days.
Before communicating personal information outside Quebec, the law requires a privacy impact assessment, or PIA (s. 17). Most cloud services and AI tools are concerned.
Any incident presenting a risk of serious injury must be reported to the Commission d’accès à l’information and to the persons concerned, then recorded in a registry (s. 3.5 and following).
When the purposes of the collection are fulfilled, the information must be destroyed or anonymized, subject to retention periods set by other laws.
The full text of the act is on LégisQuébec (sources at the bottom of the page). In case of non-compliance, it provides for administrative penalties of up to 10 million dollars or 2% of worldwide turnover, and penal fines of up to 25 million dollars or 4%.
When you dictate findings in the field, your microphone can pick up the voice of the seller, the broker or your client. It is a very real consent issue in this trade, and one inspection tools rarely address. Lumos makes it a managed feature rather than a blind spot.
Before your very first dictation, Lumos shows a consent screen spelling out the processing by OpenAI (Whisper transcription), the place of processing (United States) and the retention periods. Your consent is recorded with a timestamp and can be withdrawn at any time with a simple toggle in Settings, under Privacy.
Lumos keeps the original recording for a maximum of 7 days, or until the finding is confirmed, whichever comes first. OpenAI may keep it for up to 30 days for abuse detection, without using it to train its models. The text transcription, for its part, stays with the finding.
Law 25 rests on informed consent, and you are the one responsible for informing the people present that their voice may be captured. The Lumos documentation gives you wording ready to say out loud at the start of an inspection.
If someone present is not comfortable, you switch to text input without losing anything: every other Lumos feature works without voice dictation.
“I am going to use voice dictation to record my observations. My voice, and possibly yours, may be captured and transcribed by an automated service. If you are not comfortable with that, let me know and I will switch to text input.”
The details in the documentation: managing audio capture consent
When you prepare a proposal or deliver a report, you transmit your client’s contact details to Lumos: name, email, phone where applicable, and the address of the inspected property. Nothing more. That data is collected under your authority: Law 25 makes you the initial controller, and Lumos equips you to hold that role.
| Obligation | Who handles it, and how |
|---|---|
| Inform the client and collect their consent | You, typically through the service agreement signed before the inspection, which also informs them that their contact details are transmitted to Lumos. |
| Host and secure the data | Lumos, which encrypts it in transit and at rest, never sells it and never shares it with other inspectors. |
| Answer an access or rectification request | You, within the legal 30-day period. The built-in export lets you produce a copy quickly. |
| Guarantee data portability | Lumos: CSV or JSON export for structured data, ZIP archive for photos, audio and PDFs, straight from the Projects page. |
You remain the owner of your inspection data: Lumos acquires no rights over it and does not use it to train AI models. The full framework, including the communications Lumos may send your clients, is detailed in the privacy policy.
Lumos relies on two AI providers, and the rule is simple: they process your requests in real time, they do not learn from your data. Here is exactly what is transmitted to them.
| Provider | Role in Lumos | What is transmitted |
|---|---|---|
| Anthropic (Claude) | Finding suggestions, rewording and BNQ compliance review. | The text you typed and the inspection context: section, sub-section, property type. Processed in the United States. |
| OpenAI (Whisper) | Voice dictation transcription. | The audio file of your dictation. Processed in the United States. |
Your reports, photos, recordings and observations are not used to train any model: not Lumos’s, and not Anthropic’s or OpenAI’s under their engagements with Lumos. If that were ever to change, your explicit consent would be requested, and refusing would not affect your access to the software.
Every data communication to these providers went through a privacy impact assessment (PIA), as Law 25 requires. You can request a copy at privacy@lumos.property.
During the compliance review, only your personal findings are sent to the model. Findings from the Lumos bank are filtered out, as they are already compliant.
Dictation can be turned off and generation buttons are optional: you keep templates, the findings bank, photos, PDF output and invoicing without touching AI.
A precise posture rather than a slogan: the Lumos database is hosted in Canada (Supabase, East region). The application is served by Vercel in the United States, where the AI providers also process the data sent to them. Law 25 does not prohibit those transfers; it requires that they be assessed, governed and encrypted. That is exactly what Lumos documents.
TLS 1.3 for exchanges, AES-256 for storage, multi-factor authentication on administrative access, least-privilege access controls and regularly tested backups.
In accordance with Law 25, a privacy impact assessment was conducted before any communication of personal information outside Quebec. The information transferred is limited to what is necessary and each provider is bound by contract.
If a confidentiality incident presents a serious risk: immediate containment, notification of the Commission d’accès à l’information without delay, diligent notice to the persons concerned, entry in the internal registry and corrective measures.
Lumos’s person in charge of the protection of personal information is Sébastien Malherbe, president of Lumos Intégrité Inc., reachable at privacy@lumos.property. Every request is answered within a maximum of 30 days.
Lumos Intégrité Inc. is a Quebec company subject to the Act respecting the protection of personal information in the private sector, as modernized by Law 25, and its compliance is documented: a designated privacy officer, consent collected purpose by purpose, a privacy impact assessment before any communication outside Quebec, an incident procedure with notification to the CAI, and tooling for access, rectification and portability rights. The full privacy policy is published on the site.
There are two levels. Your own consent first: Lumos records it with a timestamp before your first dictation, and you can withdraw it at any time in the settings. Then the consent of the people present: informing them is your responsibility, and the Lumos documentation provides wording to say at the start of the inspection. If someone declines, you simply switch to text input.
The Lumos database is hosted in Canada (Supabase, East region). The application is served by Vercel in the United States, where the AI providers Anthropic and OpenAI process the data sent to them. In accordance with Law 25, every communication of personal information outside Quebec was preceded by a privacy impact assessment, transfers are limited to what is necessary, and data is encrypted in transit and at rest. The provider-by-provider detail is in the privacy policy.
You remain the owner of your inspection data and can export everything at any time: CSV or JSON for structured data, a ZIP archive for photos, audio and PDFs. When your account is closed, Lumos deletes or anonymizes your information within 90 days, subject to legal retention obligations such as the 7 years applicable to billing data.
Lumos builds Law 25 in where it actually plays out: in the agreement signed before the inspection, in the dictation in the field, and in the export of your data.
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