How Carno AI protects client data when building and operating business automation systems.

Carno AI builds internal automation and AI-enabled workflows that connect with a client's existing business systems. Security and privacy are designed into those workflows from the start, with the aim of processing only the information required to deliver the agreed outcome.

01Our role with client data

For most client automation projects, the client remains the data controller: it decides why its Personal Data is used and what the business process is intended to achieve. Carno AI normally acts as a data processor, handling that information only to build, operate and support the agreed workflow and in accordance with the client's documented instructions.

These responsibilities are supported by a Client Data Processing Agreement (DPA), documented subprocessors and client-specific processing records. Higher-risk projects receive additional privacy/risk assessment before production deployment.

Production automation systems will generally be deployed within technology accounts or infrastructure owned or controlled by the client. Carno AI is granted the level of access reasonably necessary to design, configure, test, monitor, maintain and support those systems. The client retains control of its environment and remains responsible for determining the purposes of the underlying processing.

02Security by design

Carno AI uses a risk-based security approach designed around confidentiality, integrity and availability. UK GDPR does not prescribe one universal technical configuration; organisations are expected to implement measures appropriate to the data, processing and risks involved. Carno therefore reviews controls in the context of each workflow rather than treating security as a one-time checklist.

03Infrastructure and access protection

04Data minimisation and AI

Carno AI does not treat an AI model as a destination for an entire client database. Where an AI API is useful, the workflow should send only the information needed for the specific task. Unnecessary identifiers, documents and sensitive fields should be excluded wherever practicable.

Where Carno appoints an AI/API provider to process Personal Data on behalf of a client, that provider is assessed and documented as a Carno subprocessor. Where an AI/API provider is instead contracted and controlled directly by the client, that provider forms part of the client's technology environment rather than Carno's subprocessor chain.

Carno currently supports approved commercial/API environments where appropriate to the agreed workflow. Where Carno appoints an AI/API provider to process Personal Data on behalf of a client, that provider is assessed and documented in Carno AI's Subprocessor Register. Carno does not intentionally opt client-data projects into model-training or data-sharing programmes. Provider terms and data controls remain subject to periodic review.

For workflows involving identity documents, detailed financial information, special-category data, profiling, significant automated decisions or other higher-risk processing, Carno performs additional assessment and may require a DPIA, additional safeguards or a reduced automation scope before proceeding.

05Retention and deletion

Carno aims to avoid creating unnecessary permanent copies of client information. Personal Data should be retained only for the period reasonably required for the relevant business purpose, operation, troubleshooting, security or agreed support.

Where production workflows operate within a client-controlled environment, the client remains responsible for determining the appropriate retention period as controller. Carno configures or recommends workflow-retention settings in accordance with the agreed design and the client's instructions.

Where Carno-controlled n8n infrastructure processes client Personal Data, Carno's standard execution-data target is a maximum age of 14 days unless another documented configuration is appropriate.

Temporary exports, downloads and test files should be deleted promptly when no longer required.

At the end of an engagement, Carno follows a documented offboarding process covering Carno's access to the client's environment, connected credentials, Carno-held copies of client information, handover requirements and any deletion or return obligations under the DPA. Client-owned infrastructure and the data remaining within it continue to be controlled by the client.

06Backups, resilience and recovery

For Carno-controlled infrastructure, Carno maintains backup and recovery arrangements appropriate to the relevant systems and risks. Backups are intended for resilience and recovery rather than as an alternative long-term archive.

Where production workflows operate within client-controlled infrastructure, platform availability, infrastructure resilience and underlying backup arrangements are primarily provided by the client and/or the relevant technology provider. Carno may assist with workflow-level recovery, configuration and continuity measures within the scope of the service.

Where deleted information remains temporarily within Carno-controlled protected backups, it is kept beyond ordinary use until removed through the applicable backup cycle.

07Security incidents

Carno maintains a documented Personal Data Breach & Incident Response Procedure. Suspected incidents are logged, contained and assessed promptly. Where Carno acts as a processor and becomes aware of a Personal Data Breach affecting client data, the relevant client/controller is notified without undue delay and receives material updates as the investigation develops.

For incidents originating within client-controlled systems, Carno's responsibilities are limited to the systems, access and processing within Carno's control and to the assistance obligations agreed with the client. Carno will cooperate with the client where relevant to investigation, containment and remediation.

Incident handling includes credential revocation/rotation where appropriate, preservation of relevant evidence, risk assessment, remediation and a post-incident review for material events.

08Subprocessors and international processing

Carno maintains a Subprocessor Register for providers engaged by Carno that may process client Personal Data on Carno's behalf.

Providers contracted directly by a client as part of the client's own technology environment are not automatically Carno subprocessors. This may include the client's automation platform, email provider, database/CRM, calendar services and other connected systems. Responsibility for those providers is determined by the contractual and data-processing relationship involved.

Carno may use approved providers such as Hostinger for Carno-controlled infrastructure and OpenAI for AI/API processing where applicable. The specific subprocessors used for an engagement are documented in Carno AI's current Subprocessor Register.

Carno operates as an Australian business. Where a UK client makes Personal Data accessible to Carno in Australia and the transfer constitutes a restricted transfer under UK GDPR, Carno's contractual framework anticipates an appropriate safeguard such as the UK IDTA or UK Addendum together with the required transfer assessment/data-protection test.

Where international processing results from a provider engaged directly by the client, the client remains responsible for the transfer arrangements applicable to that provider. International-transfer arrangements involving Carno or its subprocessors are assessed as part of the relevant engagement.

09Privacy governance

10Human oversight and automation risk

Carno's objective is to remove repetitive administration without unnecessarily removing human judgement. Where an automation produces an uncertain result, handles an exception or could materially affect an individual, the workflow can be designed to escalate to a person rather than make an uncontrolled decision.

Carno's standard position is to avoid solely automated decisions with legal or similarly significant effects unless the specific use case has been assessed, the client has a lawful basis and appropriate safeguards are in place.

11What Carno expects from clients

Security is shared across the overall system. Because production automation will generally operate within infrastructure owned or controlled by the client, clients remain responsible for their accounts, subscription arrangements, user permissions, underlying platform configuration where under their control, lawful use of Personal Data and the providers they contract directly.

Clients are also responsible for ensuring that Carno receives appropriate documented instructions and only the access required to provide the agreed services.

Carno encourages clients to apply multi-factor authentication where available, provide the minimum access required, promptly remove obsolete users and credentials, identify sensitive or higher-risk data during scoping, and notify Carno of relevant security or privacy requirements.

12Security reviews and assurance

Carno reviews its controls as its delivery architecture, internal infrastructure, client base and risk profile develop. Security measures may be improved or replaced as technology and threats change. Carno's current compliance foundation includes documented security, privacy, incident, retention, offboarding, transfer and DPIA processes.

Carno does not currently claim ISO 27001 certification, Cyber Essentials certification, formal UK GDPR certification or any other security certification that has not actually been obtained. Future certifications may be pursued as the business matures.

13Requesting further information

Clients and prospective clients can request relevant security/privacy information during due diligence. Where appropriate, Carno can provide its DPA, current Subprocessor Register and additional policy information, subject to confidentiality and security considerations.