As artificial intelligence tools become increasingly embedded in day-to-day operations, charities and not-for-profit (NFP) organizations are facing many of the same governance questions as public institutions. Although the “Principles for the Responsible Use of Artificial Intelligence” (the “Principles”), released on January 21, 2026, were developed for Ontario’s public sector, the framework offers valuable guidance for charities and NFPs seeking to adopt AI responsibly while maintaining public trust.
The Principles adopt a broad definition of AI drawn from Ontario’s Enhancing Digital Security and Trust Act. AI includes not only large language models (LLMs), but also automated screening tools, recommendation engines, and data analysis systems.
The Principles emphasize governance throughout the AI life cycle – from design and validation to deployment, monitoring, and eventual decommissioning. Even where an organization does not develop these systems themselves, they remain responsible for how they are selected, configured, and used. This requires clarity about its purpose and data sources once deployed.
At the core of the Principles are six interconnected values: validity and reliability, safety, privacy protection, human rights affirmation, transparency, and accountability. Each has practical implications for the charitable and NFP sector.
- Validity and reliability require that AI systems perform accurately for their intended purpose and be tested and monitored over time. Flawed or biased input data will produce flawed outcomes, regardless of how sophisticated the tool appears.
- Safety extends beyond physical harm and includes impacts on mental health, economic security, and access to services. Charities and NFPs serving vulnerable populations should ensure meaningful human oversight, particularly where decisions affect benefits eligibility, services, funding or reputation.
- Privacy protection requires a “privacy by design” approach. Charities and NFPs, for example, should confirm that there is lawful authority to collect, use, and disclose personal information, limit any personal data inputs where possible and consider techniques, such as de-identification. AI systems can challenge traditional privacy principles, and organizations must consider not only data retention policies, but also the long-term implications of using external AI platforms.
- The human rights Principle emphasizes proactive identification and mitigation of any systemic discrimination. Charities and NFPs are bound by human rights legislation and should review datasets and outcomes to prevent unintended bias in hiring, funding, or service delivery decisions.
- Transparency requires that AI use be visible and explainable. For charities and NFPs, this may include informing stakeholders when and how AI tools are being used, particularly where important decisions are made. Organizations should be able to explain, in plain language, how an AI system contributes to an outcome.
- Accountability requires clear governance structures, designated oversight responsibilities, and internal policies guiding AI use. A “human-in-the-loop” approach for any authority to make decisions helps to keep individual persons accountable rather than deferring to automated systems.
Although portions of the Principles address technical requirements more relevant to AI developers, the broader values are directly applicable to organizations that procure or rely on third-party systems. Even where a charity or NFP does not design the technology itself, it retains responsibility for how that technology is used and for the impacts it produces.
Ultimately, the Principles provide a useful roadmap for charities and NFPs seeking to align technological innovation with their legal obligations and organizational values. By adopting a life cycle approach and embedding values of privacy, fairness, transparency, and accountability into AI governance, organizations can harness emerging technologies while safeguarding the trust placed in them by donors, beneficiaries, and the public.