Access to information records, kept in Canada.

• Canada region. Each CommonWatch environment is a Dataverse environment created in Microsoft's Canada region, with datacentres in Toronto and Quebec City.
• Backups. Microsoft keeps environment backups in more than one datacentre and replicates data within the Canada geography for resilience.
• Files. Record files stay in Dataverse, or in a SharePoint library on its own site in your Canadian Microsoft 365 tenant.
• Release service. The service that rebuilds releases and renders redacted video and audio runs on Azure in Canada.
• Microsoft's exceptions. Microsoft lists services that may store some data outside the geography, including Entra ID, multifactor authentication data and Dataverse table and column names (not their contents). See Microsoft's data residency documentation.

• Single sign-on. Staff sign in with Microsoft Entra ID under your multifactor and conditional access policies.
• Roles. Analyst, Coordinator, Approver, Read-only and Custodian, each a Dataverse security role.
• Separation of duties. The person who prepared a release can't approve it. The server enforces this.
• Requesters. Requesters sign in to the requester portal and see only their own requests.

Every change to a request, its deadlines, fees and release package, and every time someone opens a record, is logged with who, what and when. Users can't edit the log, and each request's audit trail exports to Excel. Letters, evidence and releases carry SHA-256 fingerprints.

• Rebuilt from page images. An independent service rebuilds each release from page images, so no hidden text, layers or metadata are carried over.
• Local checks. The check for words left visible and the personal information finder run on the analyst's computer. Nothing is sent to an outside AI service.
• Unsafe files refused. Word and Excel files with macros or embedded objects, and legacy .doc and .xls files, are refused at upload.

• Email. Letters go from your FOI mailbox through Dataverse email.
• SharePoint. The document store has write access to its one SharePoint site only (Microsoft Graph Sites.Selected) and signs in with a Power Platform managed identity, with no stored secret.

• Platform. Microsoft Power Platform and Azure are covered by Microsoft's SOC 2 Type II and ISO/IEC 27001 reports, available from the Microsoft Service Trust Portal.
• Two Rivers Digital. SOC 2 readiness work is under way. Two Rivers Digital holds no SOC 2 report today.
• Insurance. Two Rivers Digital carries technology professional liability, network security and privacy liability and cyber incident response cover of CAD 10 million each.
• Your data. You own it, and you can export all of it at any time and when the contract ends.