Effective June 2026 

Purpose 


The City of St. Paul is committed to using Artificial Intelligence (AI) in a way that enhances public services while maintaining the highest standards of transparency, accountability, fairness, and compliance with Minnesota law. This policy establishes standards for the responsible use of AI technologies, consistent with the Minnesota Government Data Practices Act (MGDPA, Minn. Stat. § 13) and other applicable state and federal requirements.   

Definition of AI Technology 


The City of Saint Paul defines artificial intelligence (AI) as a machine-based system that, for a given set of human-defined objectives, can analyze data and generate predictions, recommendations, or decisions that influence real or virtual environments. AI systems use data inputs to identify patterns, develop models, and produce outputs that inform or automate actions. 

The City of Saint Paul defines an AI technology as any system, software, hardware, application, tool, or service that incorporates or relies on AI in whole or in part. 

Scope 


This policy applies to all City departments, employees, contractors, consultants, vendors, or anyone else working for or on behalf of the City of St. Paul that design, procure, manage, or operate AI systems. It covers both internally developed and externally procured AI tools, whether experimental, pilot, or fully deployed.  

Individual departments may adopt their own policies which may be more stringent than this policy.  Where a department has adopted such a policy, the more stringent policy governs people working within that department.  In addition, individual supervisors may restrict or prohibit the use of AI for particular tasks and/or types of work.  All such supervisor directions are binding pursuant to this policy. 

Authorized Uses of AI Technology

AI technology may be used by City staff and partners for appropriate business purposes that support efficiency, service delivery, and organizational effectiveness. Authorized uses include, but are not limited to: 

  • Drafting and refining content for grant applications, reports, memos, presentations, and emails.
  • Assisting with data analysis, such as identifying trends, summarizing information, or generating forecasts to inform decision-making.
  • Supporting administrative functions, such as scheduling assistance, drafting routine correspondence, or organizing large amounts of information.
  • Creating summaries of public comments, survey results, or meeting notes to aid in transparency and responsiveness.
  • Assisting with translation or accessibility tools to improve communication with diverse communities. 

All use of AI technology must be consistent with Minnesota law, protect data privacy, and ensure that final responsibility and approval rest with a City employee.  Employees who have questions regarding the appropriate use of AI should contact the Director of OTC or a designated representative prior to using such technology. 

Prohibited Uses of AI Technology

AI technology shall not be used in ways that create risks to civil rights, privacy, security, or public trust. Prohibited uses include, but are not limited to: 

  • Deploying AI in a manner that results in discrimination based on race, color, national origin, gender, age, disability, religion, sexual orientation, or any other protected class under local, state, or federal law.
  • Fully automating critical decisions without human oversight, including decisions that affect employment, housing, public safety, access to City services, or legal rights.
  • Using data which constitute private, nonpublic or confidential data under the Minnesota Government Data Practices Act (MGDPA) or any other applicable law.1
  • Using data which is subject to the attorney-client, physician-patient, and/or any other legally recognized privilege.
  • Engaging in surveillance or monitoring activities that violate constitutional rights or exceed lawful authority.
  • Relying on AI to provide legal, medical, or financial determinations without appropriate professional review.
  • Publishing AI-generated content as official City communication — including press releases, policy statements, legal notices, or AI-generated images for social media/newsletters — without supervisor review and approval 

Any other use of AI that undermines transparency, accountability, or public trust in City government. 

Implementation and Review 

  • All technologies, including AI technologies, used to conduct City business must be registered with OTC. Department Directors are responsible for ensuring all AI technologies in use within their departments are reported to OTC and comply with this policy. 
  • OTC shall maintain a public inventory of all AI systems approved for use by the City of Saint Paul. OTC may require a security or AI review of any system at any time.
  • The Director of OTC is responsible for overseeing AI implementation across City departments and ensuring departmental compliance with this policy. 
  • This policy will be reviewed and updated regularly if required by changes in Minnesota statutes, federal law, or advances in technology.
  • Violations to the City of St. Paul’s Artificial Intelligence (AI) Use Policy may result in disciplinary action, up to and including termination of employment or contract, in accordance with City policies and applicable laws.