Canady Realty — Artificial Intelligence Use Policy
    Effective Date: April 2026 · Prepared by Brent Canady, Broker of Record / AI Oversight Lead · Annual Review Cycle
    Policy at a Glance
    ·AI tools are disclosed to consumers
    ·Human review required before any AI content reaches clients
    ·Fair Housing Scanner on all outbound email
    ·No model training on client or brokerage data
    ·AI Oversight Lead: Brent Canady, Broker of Record
    ·Annual review minimum — more frequent if law changes
    This policy governs the responsible, ethical, and secure use of Artificial Intelligence by all agents, staff, and authorized vendors of Canady Realty. It applies to all AI tools used in connection with brokerage operations, including:
    • Consumer communications and the public-facing canadyrealty.com website
    • Property listing content and MLS data
    • Comparative Market Analyses (CMAs) and property valuations
    • Lead generation, CRM, and client relationship management
    • Social media content and marketing
    • Transaction management and document preparation
    • Internal broker intelligence and market analysis
    Canady Realty operates two primary technology systems within the scope of this policy: the GRAIL Platform (internal broker intelligence system) and canadyrealty.com (consumer-facing website). Both use AI and are governed by this policy.
    GRAIL Platform
    Canady Realty's proprietary AI-powered market intelligence system. Includes the internal broker dashboard, Ursula (broker-facing AI assistant), predictive valuation tools, and the market analysis engine.
    canadyrealty.com / ASK AI
    Canady Realty's consumer-facing website and integrated AI chat feature. The ASK AI allows consumers to ask questions about properties and the Central Texas market. It is powered by AI and identified as such.
    grail-data-sync
    The primary application database. Stores all platform-produced data: MLS listings, lead pipeline, CMA deliveries, visitor sessions, broker activity, compliance records, PII audit logs, agent assignments, and consumer AI chat sessions.
    grail-ai-worker
    The AI processing engine. Executes market analysis, CMA generation, content production, and email intelligence. Writes results to grail-data-sync. Does not independently persist primary consumer or broker data.
    MLS Data
    Property listing information sourced from MLSGrid and UnlockMLS under applicable licensing agreements. Canady Realty's MLS data scope is limited to Central Texas markets.
    Application-Level Calibration
    Canady Realty's valuation system adjusts scoring weights stored in the database based on outcome validation (predicted vs. actual sale prices). The underlying AI models are stateless inference services — they do not train on or retain brokerage or client data between sessions.
    AI Oversight Lead
    The designated person responsible for AI governance at Canady Realty.
    AI Oversight Lead
    Brent Canady, Broker of Record, is designated as the AI Oversight Lead. Responsibilities include maintaining the approved tools list, reviewing and approving new AI use cases involving client or MLS data, conducting or commissioning periodic policy reviews, and signing off on compliance reviews — recorded in the ai_compliance_signoffs system log with reviewer name, timestamp, notes, and scheduled next-review date.
    Human Review Requirement
    Human review is mandatory before any AI-generated content is:
    • Published in an MLS listing or syndicated to any property portal
    • Sent to a client or consumer
    • Used in marketing or advertising materials
    • Included in transaction documents or disclosures
    • Delivered to a consumer as a property valuation or CMA
    CMA Consumer Delivery Workflow
    All AI-generated CMAs intended for consumer delivery follow a defined review workflow enforced at the data layer. When a home valuation request is submitted, the system generates the CMA asynchronously and creates a record with status pending_review. The CMA is surfaced to the broker in the AI Compliance Center's CMA Review queue. The broker reviews the full email content, suggested value, and confidence score before any delivery action is available. On approval, the system records the broker, timestamp, and updates status to approved. No consumer-facing CMA delivery can occur without a completed broker approval record at the data layer.
    Audit Logs
    The platform maintains the following operational audit records:
    • pii_audit_log — tracks all actions involving consumer PII, including IP address and user agent
    • guardrail_activations — records every instance where the AI safety system blocked or modified a consumer response
    • ai_compliance_signoffs — records formal compliance sign-offs with reviewer, timestamp, notes, and next-review date
    • audit_logs — records system-wide compliance events including Fair Housing Scanner flags and CMA approvals
    • chat_tool_usage — records AI tool calls made during consumer and broker sessions
    Guardrail Testing
    The existence of a guardrail logging system does not confirm guardrails are performing adequately. Canady Realty commits to periodic adversarial testing of the consumer ASK AI interface — at minimum quarterly — to verify that prohibited content, steering language, and legally sensitive responses are correctly intercepted. Test results will be documented and retained.
    Data Residency Principle
    Raw MLS listing data is never written to or modified by AI processes. The grail-data-sync and grail-ai-worker systems communicate — MLS comparables flow into the processing engine for CMA generation, and AI-generated intelligence is written back — but the MLS source data layer is structurally protected from AI writes. The separation is one of residency and write permissions, not hermetic isolation.
    Approved Tools
    Agents and staff may only use AI tools approved by the AI Oversight Lead for brokerage business.
    Tool / SystemPurposeApproval Status
    GRAIL Platform / UrsulaInternal broker market intelligenceApproved — broker-facing only
    canadyrealty.com ASK AIConsumer property questionsApproved — consumer-facing, AI-disclosed
    OpenAI (GPT-4o, GPT-4o-mini)CMA generation, content analysis, investment scoringApproved via API — no model training on brokerage data
    Anthropic (Claude Sonnet 4.5, Claude Haiku 4.5)Broker chat responses, content generation, email extractionApproved via API — no model training on brokerage data
    Vendor Data Training Prohibition
    Canady Realty uses AI inference services exclusively via API. Under applicable API terms, these providers do not train their models on data submitted through API calls. Canady Realty has verified this policy and will re-verify at each annual policy review.
    Prohibited Data Inputs
    The following must never be entered into any AI tool:
    • Client Social Security numbers or full financial records
    • Settlement statements or closing documents in unapproved tools
    • MLS data in violation of MLS licensing agreements or IDX/RESO standards
    Consumer PII
    All actions involving consumer PII are logged in pii_audit_log. Consumer contact data collected through canadyrealty.com is subject to Canady Realty's Privacy Policy.
    Access Controls
    Consumer and broker AI sessions are scoped separately. The internal GRAIL broker dashboard and Ursula are not accessible to consumers. The consumer ASK AI operates under a separate session context with its own guardrail layer.
    Permitted Uses
    • Generating market analysis, comparable reports, and pricing insights for broker review
    • Drafting listing descriptions and marketing content subject to agent review before publication
    • Answering consumer property questions through the ASK AI interface, within defined scope limits
    • Extracting intelligence from market emails and MLS reports for internal broker use
    • Scoring and prioritizing investment opportunities for broker evaluation
    Agentic AI
    The GRAIL Platform's Ursula assistant operates as an agentic AI — it can execute multi-step tasks using a library of intelligence tools. Ursula is restricted to the internal broker interface and is not accessible to consumers. All Ursula outputs requiring client communication or transaction action require broker review before use.
    Consumer ASK AI Scope Limits
    The consumer ASK AI is configured with the following hard boundaries, enforced in the application layer:
    • Answers general questions about Central Texas properties and market conditions
    • Does not provide legal advice, financial advice, or binding property valuations
    • The initial disclosure message states: "I'm an AI assistant, so for contracts, pricing, or legal advice, I'll get you to a licensed agent"
    • Agent escalation is triggered client-side by keyword detection on every message. If a consumer's message contains phrases like "licensed agent," "real agent," "human agent," "connect me," or "call me" — the AI call is bypassed entirely and a hardcoded response directs the consumer to (512) 850-5405
    • High-intent signals (lead score above threshold) trigger immediate conversion prompts rather than continued AI conversation
    Prohibited Uses
    • Generating discriminatory, misleading, or deceptive content
    • Producing listing descriptions or advertisements that violate the Fair Housing Act or Texas fair housing law
    • Using AI to determine which clients to serve, qualify, or prioritize without human review
    • Entering confidential transaction documents into unapproved AI tools
    • Representing AI-generated content as human-authored where disclosure is required
    • Using AI image generation to alter the apparent demographics of a neighborhood or property surroundings
    Fair housing compliance is a critical requirement for all AI-generated content at Canady Realty.
    Mandatory Requirements
    • All AI-generated listing descriptions and marketing materials are reviewed for fair housing compliance before publication
    • AI tools are not used to target or exclude audiences based on any protected class under federal, Texas, or local law
    • AI-generated content does not include neighborhood steering language
    Fair Housing Scanner
    All outbound email content — both AI-generated and static template — passes through an automated Fair Housing Scanner before any send decision is made. The scanner checks subject lines and body copy against a dictionary of 15 prohibited phrase patterns covering 7 protected classes: familial status, religion, race and national origin, sex, disability, age, and demographic school steering.
    Block Severity
    Email is not sent. Sequence step forced to dry-run regardless of broker approval. FAIR_HOUSING_FLAG event written to audit log with severity: critical. Cannot be overridden at the UI layer.
    Warning Severity
    Email may proceed, but a FAIR_HOUSING_FLAG event is written to audit log with severity: warning for broker review. No send is blocked.
    Examples of block-severity patterns include familial status references ("perfect for families with kids"), religious proximity steering, and racial or ethnic composition references. Warning-severity patterns include potentially ambiguous language such as "up-and-coming neighborhood" and school district references that could imply demographic steering. All flag events are visible in the AI Compliance Center's Fair Housing audit trail.
    Neighborhood & Crime Data Policy
    AI-generated content never includes AI-interpreted neighborhood demographics, crime characterizations, or school district comparisons. When such information is relevant, agents cite primary sources directly (e.g., Austin PD crime data, Texas Education Agency school ratings) without AI interpretation.
    The ASK AI chat on canadyrealty.com is identified to consumers as an AI-powered tool in two places: a persistent label reading "AI-powered assistant · Responses may not be perfect" displayed throughout every conversation, and in the initial greeting message: "I'm an AI assistant, so for contracts, pricing, or legal advice, I'll get you to a licensed agent."
    Automated AI Responses to Consumers
    • Do not provide legal advice, financial advice, or binding property valuations
    • Are designed to escalate to a licensed agent for transaction-specific, pricing, or contractual questions — this escalation bypasses the AI entirely when triggered by keyword detection
    • Are subject to the same fair housing guardrails as all other AI-generated content
    All consumer chat interactions involving personal data comply with Canady Realty's Privacy Policy.
    All agents and staff are fully accountable for any AI-generated content they use, share, or publish on behalf of Canady Realty. Human review is mandatory before distribution.
    Canady Realty does not publish AI-generated content under individual agent names without agent review and approval. The brokerage reserves the right to audit AI-generated outputs for brand compliance and take corrective action.
    AI tools used for consumer-facing communications, property valuations, and marketing have been reviewed for compliance with:
    • The Fair Housing Act (42 U.S.C. § 3604)
    • Texas Real Estate License Act (TRELA) and TREC rules
    • Applicable MLS licensing agreements (MLSGrid, UnlockMLS)
    • Texas data privacy law
    Legal review is required before deploying new AI capabilities in consumer-facing or transaction-adjacent contexts.
    This policy is reviewed at minimum annually. Reviews are triggered earlier by:
    • Material changes to AI tools or vendors
    • New guidance from NAR, TREC, or applicable MLS organizations
    • Changes in federal or Texas AI or data privacy law
    • Any incident involving AI-generated content that causes or risks client harm
    Reviews are documented in the ai_compliance_signoffs system record, which includes the review date, reviewer, notes, and scheduled next-review date.
    Acknowledgment
    By using any AI tool in connection with Canady Realty business, agents and staff confirm they have read, understood, and agree to comply with this policy.
    Drafted with reference to the NAR Brokerage AI Policy Kit (2026) and the GRAIL Platform technical architecture. Final version subject to legal review.
    Questions About This Policy
    AI Oversight Lead: Brent Canady, Broker of Record · Canady Realty, LLC · 501 W Crestland Dr, Austin, TX 78752