
AI Use & Governance Disclosure
Last updated: December 15, 2021
1. Purpose
This document describes how Routable, Inc. (“Routable”) uses artificial intelligence (“AI”) and machine-learning (“ML”) capabilities within its accounts payable platform, and the controls Routable has in place around data accuracy, transparency, privacy, fairness, security, and vendor oversight. It is intended to supplement — not replace — Routable’s Data Processing Addendum, Privacy Policy, Sub-Processor List, and Security Practices.
2. Scope: Where AI Is Used in Routable
Routable uses AI and ML in two categories of activity: Customer-Facing AI Features and Internal AI Tools. Customer Data flows only into the Customer-Facing Features as described in § 2.1.
2.1 Customer-Facing AI Features
Invoice Capture / OCR
Extracts structured fields (vendor, amount, line items, dates) from invoice files uploaded to the Routable Inbox
Rossum
Invoice file contents only
Predictive Invoice Coding
Suggests GL codes, departments, and other coding fields for invoices to accelerate AP workflows
Kaunt
Invoice header/line metadata and historical coding decisions
2.2 Internal AI Tools (No Customer Data)
Routable also uses third-party AI tools internally for data analysis and reporting (e.g., OpenAI). Customer Data is not used to train these models, and Routable does not share or submit customer-identifying records with these tools. See the Sub-Processor List for current details about the Sub-Processors with whom Routable currently shares Customer Data.
3. AI Governance Controls
3.1 Data Accuracy & Model Performance
- Continuous accuracy monitoring. Routable monitors output quality for each AI feature (extraction accuracy for OCR; coding-suggestion acceptance rates for predictive coding). Regressions trigger an internal review with the vendor.
- Vendor accuracy commitments. Our AI sub-processors provide accuracy benchmarks and model performance reporting under their commercial agreements with Routable.
- Customer feedback loop. When a user overrides an AI suggestion, the correction is captured as ground truth, both for the customer’s own future suggestions and (where contractually permitted — see §3.4) for model improvement.
3.2 Transparency & Explainability
- AI suggestions are clearly labeled in the Routable UI; users can identify which fields were populated by AI versus entered manually.
- All AI outputs are advisory. Predictive coding produces a suggestion — never an irrevocable decision. OCR-extracted fields are reviewable and editable before any payment is initiated.
- No automated decisions with legal or significant effect. Routable’s AI features do not make decisions that produce legal or similarly significant effects on individuals (e.g., denying a payment, rejecting a vendor) without human review.
3.3 Human Oversight (Human-in-the-Loop)
Routable’s AI features are designed for human-in-the-loop operation:
- OCR extraction is presented to the user for review before any downstream action.
- Predictive coding routes suggestions through the customer’s standard review and approval workflow. Depending on the customer’s confidence-threshold configuration and approval rules, suggestions may be auto-applied below a configured confidence floor; in all cases, the customer’s approval workflow gates the actual disbursement of any payment.
- Customers retain full ability to disable AI suggestions and override individual suggestions at any time.
3.4 Privacy & Data Handling
- Data minimization. Only the data fields necessary for the AI feature’s function are transmitted to the AI sub-processor. For predictive coding, this is invoice header/line metadata and prior coding decisions; it does not include payment instrument details (bank account numbers, card data) or sensitive PII (SSN, driver’s license).
- Model training on Customer Data. Kaunt may use Customer Data to improve its models only on an aggregated and/or consented basis, in accordance with the contractual terms between Routable and Kaunt.
- Retention. AI sub-processors retain data only for the period necessary to provide the service or to comply with their own legal obligations. See the relevant sub-processor’s privacy policy linked from the Routable Sub-Processor List.
- Customer instructions and DSARs. Customer Data deletion, access, and rectification requests under GDPR / CCPA / CPRA are passed through to AI sub-processors as instructed. See Privacy Policy.
3.6 Security
- Encryption. Data in transit between Routable and AI sub-processors is encrypted using TLS 1.2 or higher. Data at rest within sub-processor systems is encrypted per their attested security programs.
- Access controls. Sub-processor access is limited to scoped service accounts with credentials rotated under Routable’s standard schedule. No customer or sub-processor employee has standing access to Routable’s production data stores.
- Sub-processor security posture. Each AI sub-processor is required to maintain industry-standard certifications (e.g., SOC 2 Type II, ISO 27001) appropriate to its services. Current attestations are reviewed during onboarding and at least annually thereafter.
- Incident response. AI sub-processors are contractually required to notify Routable of security incidents affecting Customer Data. Routable’s customer notification obligations are described in DPA §4 (Security Measures and Security Incident Response).
- Routable’s overall security posture. See security.routable.com for current certifications and the Trust Center.
3.7 Vendor Governance & Due Diligence
Before engaging any AI sub-processor, Routable conducts a documented review covering:
- Security certifications and attestations (SOC 2, ISO 27001, etc.).
- Privacy posture, including GDPR and U.S. state-law alignment, training-data practices, and data residency.
- AI-specific risk: model inputs/outputs, training-data sources and automated decision-making scope.
- Financial and operational stability appropriate to the criticality of the integration.
Sub-processors are reviewed at least annually thereafter, and the Sub-Processor List is the authoritative public record of current engagements. Customers receive notice of new sub-processors via the mechanism described in DPA §3 (Subprocessing).
3.8 Customer Rights, Opt-Out, and Notice
- Disabling AI features. Customers may disable AI-driven coding suggestions at the workspace level on request to Routable Support.
- Opting out of model improvement. Customers may opt their workspace out of any contractually permitted model-improvement uses by contacting privacy@routable.com.
- Notice of material changes. Material changes to Routable’s use of AI, including new AI sub-processors, new customer-facing AI features, or changes to training-data practices, will be communicated through Routable’s standard sub-processor notice mechanism and reflected in this disclosure.