---
title: "Reasonable Steps (Informotion Pty Ltd)"
url: "https://ailawframework.com/software/reasonable-steps"
type: "software_profile"
site: "AI Law Framework"
id: "reasonable-steps"
vendor: "Informotion Pty Ltd"
category: "Legal-specific"
segment: "Compliance and privacy"
confidence: "medium"
last_reviewed: "2026-09-27"
---

# Reasonable Steps (Informotion Pty Ltd)

> Casework software for Australian statutory access requests under Freedom of Information, GIPA and RTI regimes, from lodgement to release, built on Microsoft Power Platform with discovery and classification through…

Canonical page: https://ailawframework.com/software/reasonable-steps  
Last reviewed: 2026-09-27

Site index for agents: https://ailawframework.com/llms.txt

Plan covered: Reasonable Steps statutory access casework, licensed through Microsoft Marketplace and run in the customer's own Microsoft tenant. The EncompaaS discovery platform and the Azure AI services it calls need separate review.

Casework software for Australian statutory access requests under Freedom of Information, GIPA and RTI regimes, from lodgement to release, built on Microsoft Power Platform with discovery and classification through EncompaaS.

## Capabilities

- Knowledge search
- Matter management
- Compliance monitoring
- eDiscovery document review
- Document automation
- Redaction

## Key facts

| Fact | Value |
| --- | --- |
| Deployment | Private cloud |
| Hosting regions | Unknown |
| Australian region | Unknown |
| Model providers | Microsoft Azure AI Language (document redaction on the released copy), Microsoft Azure AI Document Intelligence (scanned material), Microsoft Purview (sensitivity labels read and written back), EncompaaS on Microsoft Azure (auto classification, entity extraction, summary, table cognition, image OCR), OpenAI, machine learning, contract extraction and Azure Cognitive Services, named as EncompaaS insight providers in the vendor's architecture diagram |
| Training on customer content | Unknown |
| Retention | The terms of use state that Reasonable Steps runs in the customer's own Microsoft tenant, reaches the customer's own systems of record under the customer's own permissions, that the customer remains responsible for its records, retention obligations and access controls, and that Informotion does not take custody of customer content. The case records, decisions and search ledger sit in Microsoft Dataverse. No retention period, no telemetry retention and no support-copy retention is published for any layer. |
| Integrations | OpenText Content Manager (TRIM), Microsoft SharePoint, Microsoft Exchange, Microsoft OneDrive, corporate file shares, relational databases and line-of-business systems over REST via EncompaaS, Microsoft Purview, Microsoft Entra ID, Microsoft Dataverse, Microsoft Power Pages, Microsoft Marketplace |
| Legal content coverage | Jurisdiction packs are held as data records covering the Act and its citation, the clock basis, the public holiday set, permitted extensions and their triggers, clock-pause events, the decision model with its section numbers, the fee and charge schedule, the review pathway and the disclosure-log rules. The site publishes the New South Wales GIPA and Commonwealth FOI packs side by side. The terms state the statutory descriptions on the site are not legal advice and not a substitute for reading the Act, and that agency delegations and policies apply on top of them. It is not a legal-research library. |
| Pricing | The product page states Reasonable Steps is licensed through Microsoft Marketplace and runs inside the customer's own Microsoft tenant, and the terms of use state it is licensed, not sold, with the signed agreement governing the commercial relationship. No price, unit, plan or Marketplace listing appears on the three pages the site map returned, and nothing published states whether the EncompaaS licence and the Azure AI service consumption are included or must be procured separately. |
| Australian presence | Yes. Published publisher and contracting entity is Informotion Pty Ltd, ABN 41 161 716 007, of Level 12, 50 Carrington Street, Sydney NSW 2000, stated in the terms of use (last updated 2 August 2026), which are governed by the laws of New South Wales with the courts of that state having jurisdiction. No ACN was published on the pages read. The product is built for Australian statutory access regimes and the corporate home page states the client base spans Australia, the UK and Ireland and the United States. |
| Website | https://reasonablesteps.com.au/ |

## What the research found

| Topic | Status | Finding | Open question | Sources |
| --- | --- | --- | --- | --- |
| Product and plan covered | Public claim only | The terms of use state Reasonable Steps is a product of Informotion Pty Ltd, is licensed rather than sold, and that the right to use it comes from a signed agreement which prevails over anything on the website. The website is described by the vendor as marketing material, not advice and not an offer to contract, with nothing on it forming part of any agreement unless repeated in a signed document. The product covers lodgement through to release for FOI, GIPA and RTI casework. | Provide the licence agreement and order form, and confirm which components - the Power Pages portal, the Power Apps code app, the Dataverse solution, the EncompaaS configuration and the Azure AI services - are inside the licence and which we procure ourselves. | [Reasonable Steps - Terms of use (Informotion Pty Ltd, ABN 41 161 716 007), last updated 2 August 2026](https://reasonablesteps.com.au/terms.html); [Reasonable Steps - product site: why it exists, how it works, jurisdictions, architecture and licensing](https://reasonablesteps.com.au/) |
| Deployment and tenancy | Public claim only | The terms of use state Reasonable Steps runs in the customer's own Microsoft tenant and reaches the customer's own systems of record under the customer's own permissions, that the customer remains responsible for its records, retention obligations and access controls, and that Informotion does not take custody of customer content. The product page adds that it is licensed through Microsoft Marketplace, that the casework interface is a Microsoft Power Apps code app with Microsoft Dataverse holding requests, decisions and the search ledger, and that EncompaaS on Microsoft Azure discovers and classifies in place with nothing copied out of the source systems. No multi-tenant hosted option is published, so the deployment is recorded here as a customer-tenant private-cloud install. | Which components sit inside our own tenant and subscription, and which run in an Informotion or EncompaaS tenant - specifically the EncompaaS service and every Azure AI endpoint it calls? | [Reasonable Steps - Terms of use (Informotion Pty Ltd, ABN 41 161 716 007), last updated 2 August 2026](https://reasonablesteps.com.au/terms.html); [Reasonable Steps - product site: why it exists, how it works, jurisdictions, architecture and licensing](https://reasonablesteps.com.au/) |
| What the product does and which parts use models | Public claim only | The product page describes estate-wide search through EncompaaS under the officer's own permissions, a custodian questionnaire for material outside a governed system, a Search Ledger that is 'append only: one entry per query, never edited' with system, query, hit count, timestamp and attribution, ending in a certificate of search that is signed, countersigned and hashed over the whole ledger, review after deduplication, thread collapse and near-duplicate grouping, a delegation check before a decision can issue, a schedule of documents that builds as the officer works, and a statement of reasons that drafts from the decisions already on file. The AI components named are third-party: EncompaaS for auto classification, entity extraction, summary, table cognition and image OCR, Azure AI Language for document redaction on the released copy with Azure AI Document Intelligence for scanned material, and Microsoft Purview sensitivity labels read as evidence and written back. Exemption suggestions are described as tracing to a governed classification rather than to a generative model. No generative or large-language-model component is described anywhere on the pages read. | Is there any generative or large-language-model step in the product - in the statement of reasons, the schedule of documents or the review surface - and if so which service performs it? | [Reasonable Steps - product site: why it exists, how it works, jurisdictions, architecture and licensing](https://reasonablesteps.com.au/); [What is EncompaaS? - vendor explainer for the discovery and classification platform underneath the product](https://reasonablesteps.com.au/encompaas.html) |
| Jurisdictions and statutory configuration | Public claim only | The product page publishes New South Wales GIPA and Commonwealth FOI packs side by side, with the Act, statutory clock (20 working days on the New South Wales public holiday set against 30 calendar days), application fee ($30 against none since 2010), charges for own personal information, decision model (a section 12 presumption in favour of disclosure with the section 14 table and Schedule 1 conclusive presumptions against Division 2 unconditional and Division 3 conditional exemptions subject to the section 11A(5) public interest test) and review path (internal, then IPC, then NCAT against internal, then IC, then the ART). A jurisdiction pack is described as a data record, so adding or switching a jurisdiction is configuration rather than code. Queensland, Victorian, Tasmanian, Western Australian, South Australian, Northern Territory and ACT packs are not published as shipping. | Which jurisdiction packs exist today as shipped configuration, who maintains them when an Act, a fee schedule or a public holiday set changes, and how quickly is that change delivered to our tenant? | [Reasonable Steps - product site: why it exists, how it works, jurisdictions, architecture and licensing](https://reasonablesteps.com.au/); [Reasonable Steps - Terms of use (Informotion Pty Ltd, ABN 41 161 716 007), last updated 2 August 2026](https://reasonablesteps.com.au/terms.html) |
| Licence, fees and procurement | Public claim only | The terms of use state the software is licensed, not sold, that the right to use it comes from the signed agreement, and that the signed agreement prevails over the website. The product page states licensing is through Microsoft Marketplace. No price, unit, minimum term or Marketplace offer identifier is published on any page read, and the site map returned no pricing page. | Provide the Microsoft Marketplace offer identifier and an itemised quote - licence unit, minimum term, implementation, and whether the EncompaaS licence and Azure AI consumption are billed separately or draw down our Microsoft commitment. | [Reasonable Steps - Terms of use (Informotion Pty Ltd, ABN 41 161 716 007), last updated 2 August 2026](https://reasonablesteps.com.au/terms.html); [Reasonable Steps - product site: why it exists, how it works, jurisdictions, architecture and licensing](https://reasonablesteps.com.au/); [Reasonable Steps site URL list - firecrawl map of reasonablesteps.com.au returning three URLs (index, encompaas.html, terms.html), used for the absence findings](https://reasonablesteps.com.au) |
| Published quality evidence | Public claim only | No accuracy, recall or evaluation evidence for the classification-derived exemption suggestions is published on any page read. The figures on the product page describe the statutory access system rather than the product and are attributed to third parties: more than 130,000 requests a year with volume up 25 per cent and cost up 14 per cent, and 27 per cent of decisions outside the statutory clock (OAIC Annual Report 2024-25 Volume 2); four in five audited Commonwealth requests unable to evidence what was searched (Australian National Audit Office, 20 May 2026); and 63 per cent of agencies using a spreadsheet with only 26 per cent using a case management system (OAIC FOI Practitioners' Survey 2024). The terms state the overview video and every screenshot use invented demonstration data, and that the departments, officers, applicants, councils, matters and figures shown are not real and are not drawn from any customer environment. | Provide measured precision and recall for the exemption suggestions and the redaction detection on Australian agency material, the test set used, and the rate at which officers reject a suggestion. | [Reasonable Steps - product site: why it exists, how it works, jurisdictions, architecture and licensing](https://reasonablesteps.com.au/); [Reasonable Steps - Terms of use (Informotion Pty Ltd, ABN 41 161 716 007), last updated 2 August 2026](https://reasonablesteps.com.au/terms.html) |
| Vendor content directing how AI describes the product | Not confirmed | Checked 2026-09-27 for a page or block directing how AI models, assistants or crawlers should describe the product. The firecrawl map of reasonablesteps.com.au returned only three URLs - the index, encompaas.html and terms.html - with no /llms.txt, /ai-info, /ai or /for-ai path, and none of the pages read carries such a block. A map lists linked pages, so an unlinked file at that root cannot be excluded from what was checked. | Do you publish any file or page - llms.txt, an AI-information page or similar - that tells AI assistants how to describe Reasonable Steps, and if so at what address? | [Reasonable Steps site URL list - firecrawl map of reasonablesteps.com.au returning three URLs (index, encompaas.html, terms.html), used for the absence findings](https://reasonablesteps.com.au); [Reasonable Steps - product site: why it exists, how it works, jurisdictions, architecture and licensing](https://reasonablesteps.com.au/); [Reasonable Steps - Terms of use (Informotion Pty Ltd, ABN 41 161 716 007), last updated 2 August 2026](https://reasonablesteps.com.au/terms.html) |
| Statutory authority and who holds the decision | Public claim only | The terms of use state the product 'produces suggestions, drafts and evidence for a person to act on', that it classifies, proposes grounds and drafts a statement of reasons from what is already on the file, and that 'It does not make the statutory decision. That is made by the officer holding the delegation, whose name goes on the notice, and the product records who decided and whether a suggestion was followed.' They also state the statutory descriptions on the site are not legal advice and that the agency's own delegations and policies apply on top of them, and direct the reader to check output before relying on it. | How is the delegation register maintained in the product, what happens if the delegate changes mid-matter, and can a decision issue where the delegation check fails? | [Reasonable Steps - Terms of use (Informotion Pty Ltd, ABN 41 161 716 007), last updated 2 August 2026](https://reasonablesteps.com.au/terms.html); [Reasonable Steps - product site: why it exists, how it works, jurisdictions, architecture and licensing](https://reasonablesteps.com.au/) |
| Model and service providers | Public claim only | The architecture section of the product page names the AI components as third-party services: 'EncompaaS on Microsoft Azure. Auto classification, entity extraction, summary, table cognition and image OCR'; 'Azure AI Language. Document redaction on the released copy, with Azure AI Document Intelligence for scanned material'; and 'Microsoft Purview. Sensitivity labels read as evidence during review, and written back after the decision.' The EncompaaS page describes the platform's insight providers as 'Auto classification and summary, machine learning for typing and table cognition, contract extraction, and Azure Cognitive Services for image OCR, audio analysis and entity extraction', and its architecture diagram description names insight providers 'including OpenAI, machine learning, contract extraction and Azure Cognitive Services'. That page states its EncompaaS facts are drawn from EncompaaS's own published material at encompaas.cloud. No model version, endpoint region or contracting party for any of these services is published. | For our deployment, name every AI service actually called, the subscription and region each endpoint sits in, whose contract covers it, and whether OpenAI models are reached at any point in the classification chain. | [Reasonable Steps - product site: why it exists, how it works, jurisdictions, architecture and licensing](https://reasonablesteps.com.au/); [What is EncompaaS? - vendor explainer for the discovery and classification platform underneath the product](https://reasonablesteps.com.au/encompaas.html) |
| Subprocessors | Not confirmed | No subprocessor list, register or dated table is published; the site map returned three URLs and none of them is a subprocessor or security page. The parties named in the architecture are Microsoft (Power Pages, Power Apps, Dataverse, Azure, Purview, Entra ID, Azure AI Language, Azure AI Document Intelligence), EncompaaS Pty Ltd and OpenText. Because the product is stated to run in the customer's own tenant, whether any of these is Informotion's subprocessor or the agency's own supplier is not established on the pages read. | Provide a dated list of every party that processes our content or metadata for this product, stating for each whether it is your subprocessor or our own supplier, and our notice and objection rights. | [Reasonable Steps - product site: why it exists, how it works, jurisdictions, architecture and licensing](https://reasonablesteps.com.au/); [Reasonable Steps site URL list - firecrawl map of reasonablesteps.com.au returning three URLs (index, encompaas.html, terms.html), used for the absence findings](https://reasonablesteps.com.au) |
| Training on customer content | Public claim only | The terms of use state that Reasonable Steps runs in the customer's own Microsoft tenant and that 'We do not take custody of your content', and the product page states content never moves and that EncompaaS discovers and classifies in place with nothing copied out of the source systems. Neither document says anything about model training, tuning or product improvement, in either direction, and no statement covers the Azure AI and EncompaaS services that read the content. The Informotion corporate privacy policy was not relied on here because the source URL of the copy read could not be confirmed. | Will you warrant that no agency content, classification output, exemption decision or ledger entry is used to train, tune or evaluate any model, and confirm the equivalent position for EncompaaS and each Azure AI service called? | [Reasonable Steps - Terms of use (Informotion Pty Ltd, ABN 41 161 716 007), last updated 2 August 2026](https://reasonablesteps.com.au/terms.html); [Reasonable Steps - product site: why it exists, how it works, jurisdictions, architecture and licensing](https://reasonablesteps.com.au/) |
| Feedback and quality monitoring | Not confirmed | The product records a quality signal by design: the terms state the product 'records who decided and whether a suggestion was followed', and the product page states 'The officer decides, and the log records whether the suggestion was followed'. Nothing published states whether that accept-or-reject signal is visible to Informotion or EncompaaS, whether it leaves the customer tenant, or whether it is used to adjust classification. | Does the record of whether an officer followed a suggestion leave our tenant, and is it used to tune EncompaaS classification or any Azure AI model? | [Reasonable Steps - Terms of use (Informotion Pty Ltd, ABN 41 161 716 007), last updated 2 August 2026](https://reasonablesteps.com.au/terms.html); [Reasonable Steps - product site: why it exists, how it works, jurisdictions, architecture and licensing](https://reasonablesteps.com.au/) |
| Retention of case records, ledger and telemetry | Public claim only | The terms of use state the customer remains responsible for its records and retention obligations and that Informotion does not take custody of customer content; the product page states Microsoft Dataverse holds every request, every decision and every line of the search ledger. No retention period is published for the Dataverse case store, the append-only Search Ledger, the certificates of search, the redacted release copies or any product telemetry, and no statement addresses how long a certificate of search must be kept to remain evidentiary. | State the default retention and archiving behaviour for the Dataverse case records, the Search Ledger, the certificates and the release packs, what telemetry you retain outside our tenant, and for how long. | [Reasonable Steps - Terms of use (Informotion Pty Ltd, ABN 41 161 716 007), last updated 2 August 2026](https://reasonablesteps.com.au/terms.html); [Reasonable Steps - product site: why it exists, how it works, jurisdictions, architecture and licensing](https://reasonablesteps.com.au/) |
| Deletion and disposal | Not confirmed | By the published design, deletion is the agency's own operation: the product runs in the agency's tenant, the records sit in the agency's Dataverse, and the terms state the agency remains responsible for its records and retention obligations while Informotion does not take custody of content. That leaves undisclosed what Informotion or EncompaaS holds that the agency cannot delete itself - support copies, logs, classification indexes or diagnostic data - and there is no deletion undertaking or certificate published. | On termination or on our instruction, what do you or EncompaaS delete from outside our tenant, in what period, and will you certify it in writing? What happens to the append-only ledger when a disposal authority requires destruction? | [Reasonable Steps - Terms of use (Informotion Pty Ltd, ABN 41 161 716 007), last updated 2 August 2026](https://reasonablesteps.com.au/terms.html); [Reasonable Steps - product site: why it exists, how it works, jurisdictions, architecture and licensing](https://reasonablesteps.com.au/) |
| Vendor access to agency content | Not confirmed | Nothing on the pages read states whether Informotion or EncompaaS personnel can access the deployed application or the agency's content during implementation, support or upgrade, from which countries, under what approval, or whether such access is logged and visible to the agency. The terms state only that the product runs in the agency's tenant under the agency's permissions and that Informotion does not take custody of content. The corporate home page states the client base spans Australia, the UK and Ireland and the United States, which speaks to the client base rather than to support locations. | Which Informotion and EncompaaS personnel can access our tenant or our content during implementation and support, from which countries, under what ticketed approval, and can we receive that access log? | [Reasonable Steps - Terms of use (Informotion Pty Ltd, ABN 41 161 716 007), last updated 2 August 2026](https://reasonablesteps.com.au/terms.html); [Informotion - corporate home page listing Reasonable Steps as an Informotion product](https://informotion.com.au) |
| Access control and permission model | Public claim only | The terms state the product reaches the agency's own systems of record under the agency's own permissions and that the agency remains responsible for its access controls. The product page states Microsoft Entra ID carries the identity from the portal down to the record so that 'a search returns what that officer could already open, and nothing else', and that a delegation check must pass before a decision can issue. The public Power Pages portal is described as taking anonymous lodgement. No role model, segregation-of-duties matrix or audit-log export description is published. | Show the role model for officer, delegate, countersigner and administrator, how the anonymous portal is separated from casework, and what an exported audit log contains. | [Reasonable Steps - Terms of use (Informotion Pty Ltd, ABN 41 161 716 007), last updated 2 August 2026](https://reasonablesteps.com.au/terms.html); [Reasonable Steps - product site: why it exists, how it works, jurisdictions, architecture and licensing](https://reasonablesteps.com.au/) |
| Encryption and key management | Not confirmed | No encryption statement appears on any page read. The only cryptographic statement is about evidentiary integrity rather than confidentiality: the certificate of search is 'signed, countersigned and hashed', with the hash computed over the whole ledger so that altering any entry changes it. Nothing states the algorithms used, how signing keys are held, or whether customer-managed keys are available for the Dataverse store. | State the encryption at rest and in transit for the Dataverse case store, the release packs and the EncompaaS indexes, the hash and signing algorithms used for the certificate, and where the signing keys are held. | [Reasonable Steps - product site: why it exists, how it works, jurisdictions, architecture and licensing](https://reasonablesteps.com.au/) |
| Independent assurance - and what it covers | Public claim only | No assurance report, certification or independent assessment of Reasonable Steps itself is published. The product page carries a heading 'Assessed to PROTECTED' whose body text describes assessments of other parties: 'Microsoft Azure and Microsoft 365 are independently IRAP assessed for workloads up to and including PROTECTED, most recently in March 2026. Power Apps and Power Automate are named in scope of the ASD Blueprint for Secure Cloud.' The EncompaaS page states EncompaaS is 'ISO 27001 certified, with the platform provisioned from Microsoft Azure', attributing that to EncompaaS's own published material. The ISG Microsoft Partner Ecosystem quadrant recognition and the Microsoft partner designations on the corporate page are about Informotion, not this product. | Has Reasonable Steps itself been IRAP assessed, penetration tested or certified? If not, what assurance covers the code app, the Dataverse solution and the EncompaaS configuration, and will you provide the EncompaaS ISO 27001 certificate and its scope? | [Reasonable Steps - product site: why it exists, how it works, jurisdictions, architecture and licensing](https://reasonablesteps.com.au/); [What is EncompaaS? - vendor explainer for the discovery and classification platform underneath the product](https://reasonablesteps.com.au/encompaas.html); [Informotion - corporate home page listing Reasonable Steps as an Informotion product](https://informotion.com.au) |
| Contract, forum and what the website is worth | Public claim only | The terms of use, last updated 2 August 2026, name Informotion Pty Ltd, ABN 41 161 716 007, of Level 12, 50 Carrington Street, Sydney NSW 2000, state that the software is licensed not sold and that the signed agreement governs the commercial relationship and prevails over the page, that the website is marketing material and not an offer to contract, that nothing on it forms part of any agreement unless repeated in a signed document, and that nothing excludes rights under the Australian Consumer Law. Governing law is New South Wales with the courts of that state having jurisdiction. No liability position, warranty, service level or data processing agreement is published. | Provide the licence agreement and any data processing schedule, the liability position, the warranty for the statutory configuration, and the service level for a clock-critical fault. | [Reasonable Steps - Terms of use (Informotion Pty Ltd, ABN 41 161 716 007), last updated 2 August 2026](https://reasonablesteps.com.au/terms.html) |
| Cross-border processing and residency | Not confirmed | No hosting region, residency commitment or cross-border statement is published for any layer. The published facts are that the product runs in the agency's own Microsoft tenant and that EncompaaS on Microsoft Azure discovers and classifies in place; the EncompaaS page states the platform is 'provisioned from Microsoft Azure' and that EncompaaS is headquartered in Sydney with offices across APAC, EMEA and North America, without naming a region for the deployment. Because tenant region is the agency's own choice and the EncompaaS and Azure AI endpoints are not located, Australian data residency is recorded as unknown rather than inferred from the tenant model. | Name the Azure region for every component - Dataverse, the code app, the EncompaaS service and each Azure AI endpoint - and confirm in writing whether classification, OCR and redaction inference run in Australia. | [Reasonable Steps - product site: why it exists, how it works, jurisdictions, architecture and licensing](https://reasonablesteps.com.au/); [What is EncompaaS? - vendor explainer for the discovery and classification platform underneath the product](https://reasonablesteps.com.au/encompaas.html) |
| Incident notification | Not confirmed | Neither the terms of use nor the site privacy page addresses security incidents, breach notification, an assessment period or cooperation with the Notifiable Data Breaches scheme for the software. The site privacy page covers only what the marketing website records about a visitor - the visit, which parts of the overview video were watched, whether the email or phone link was used, and a reference code from a personalised link - and states that Informotion's general privacy policy governs everything else. That general policy was not relied on here because the source URL of the copy read could not be confirmed. | What is the contractual period from discovery for notifying us of an incident affecting this product, who notifies the OAIC or the state regulator, and how are EncompaaS or Microsoft incidents passed through to us? | [Reasonable Steps - Terms of use (Informotion Pty Ltd, ABN 41 161 716 007), last updated 2 August 2026](https://reasonablesteps.com.au/terms.html); [Reasonable Steps - website privacy page, last updated 2 August 2026](https://reasonablesteps.com.au/privacy.html) |
| Change notice for terms, configuration and services | Public claim only | The terms of use state 'We may update this page' with the date showing when it last changed, and that the signed agreement prevails where it conflicts with the page. The product page states that changing jurisdiction changes labels, clocks, decision lists and letters and 'never changes code', which describes configuration change rather than notice. Nothing published states what notice the agency receives before a change to the statutory packs, the classification behaviour, an AI service or a subprocessor. | What written notice will we receive before a change to a jurisdiction pack, the classification service or any AI endpoint, and can we pin a configuration version for matters already running? | [Reasonable Steps - Terms of use (Informotion Pty Ltd, ABN 41 161 716 007), last updated 2 August 2026](https://reasonablesteps.com.au/terms.html); [Reasonable Steps - product site: why it exists, how it works, jurisdictions, architecture and licensing](https://reasonablesteps.com.au/) |
| Exit and evidentiary continuity | Not confirmed | No termination, export or transition provision is published. The relevant published facts are that the records sit in the agency's own Microsoft Dataverse, that the Search Ledger is 'Append only, and exportable in full', that the certificate of search is an exportable evidence artefact, and that the licence comes from a signed agreement not published on the site. Whether a certificate of search remains verifiable once the licence ends, and what happens to the hash chain, is not addressed. | On exit, what do we keep and in what format, and can a certificate of search and its ledger hash still be verified by a tribunal after the licence ends and the application is removed? | [Reasonable Steps - product site: why it exists, how it works, jurisdictions, architecture and licensing](https://reasonablesteps.com.au/); [Reasonable Steps - Terms of use (Informotion Pty Ltd, ABN 41 161 716 007), last updated 2 August 2026](https://reasonablesteps.com.au/terms.html) |
| Connectors and what they reach | Public claim only | The product page states one search strategy runs across the records estate through EncompaaS, reaching OpenText Content Manager, Microsoft SharePoint, Exchange, OneDrive and corporate file shares under the officer's own permissions, with nothing copied out of them, and that a custodian questionnaire covers material held outside a governed system while a decision not to search a system is recorded with its reason. The EncompaaS page adds connectors to relational databases and line-of-business systems over REST, on premises or cloud, and a two-way exchange with Microsoft Purview. Microsoft Entra ID carries the officer's identity down to the record. | Which connectors are in scope of our licence, what permissions does each require in our tenant, and what happens to a source system that has no connector - is it recorded as unsearched with a reason? | [Reasonable Steps - product site: why it exists, how it works, jurisdictions, architecture and licensing](https://reasonablesteps.com.au/); [What is EncompaaS? - vendor explainer for the discovery and classification platform underneath the product](https://reasonablesteps.com.au/encompaas.html) |
| Open-web retrieval | Not confirmed | Nothing on the pages read describes any open-web retrieval. The search described runs across the agency's own records estate through EncompaaS connectors, and the public element is an outward-facing Power Pages portal for applicants rather than an inbound web lookup. Whether any classification, OCR or redaction step calls a service outside the agency's tenant is not stated. | Does any step - classification, entity extraction, OCR, redaction or the statement of reasons - send agency content to a service outside our tenant, and does any component query the open web? | [Reasonable Steps - product site: why it exists, how it works, jurisdictions, architecture and licensing](https://reasonablesteps.com.au/); [What is EncompaaS? - vendor explainer for the discovery and classification platform underneath the product](https://reasonablesteps.com.au/encompaas.html) |
| What the product does on its own | Public claim only | The terms state the product produces suggestions, drafts and evidence for a person to act on and does not make the statutory decision. The product page states the delegation is checked before a decision can issue, that the officer decides and the log records whether the suggestion was followed, and that release is published to the disclosure log. The Search Ledger writes itself as the search runs and is append-only, which is an automated record rather than an action on a third party. No autonomous agent, no automatic release and no automatic notice issue is described. | Which steps can execute without an officer pressing a button - ledger entries, clock calculations, disclosure-log publication, applicant notifications - and can any of them be disabled? | [Reasonable Steps - Terms of use (Informotion Pty Ltd, ABN 41 161 716 007), last updated 2 August 2026](https://reasonablesteps.com.au/terms.html); [Reasonable Steps - product site: why it exists, how it works, jurisdictions, architecture and licensing](https://reasonablesteps.com.au/) |
| Human review before reliance | Public claim only | The terms state the statutory decision is made by the officer holding the delegation, whose name goes on the notice, that the product records who decided and whether a suggestion was followed, and instruct the reader to 'Check output before you rely on it.' The product page states review is keyboard first, every suggestion traces to a governed classification rather than a pattern match, and the statement of reasons drafts from decisions already on file with each ground traced back to the document that produced it. | Can an exemption suggestion be accepted in bulk, does the product require the officer to open the document before accepting, and does the statement of reasons record which grounds were drafted rather than written? | [Reasonable Steps - Terms of use (Informotion Pty Ltd, ABN 41 161 716 007), last updated 2 August 2026](https://reasonablesteps.com.au/terms.html); [Reasonable Steps - product site: why it exists, how it works, jurisdictions, architecture and licensing](https://reasonablesteps.com.au/) |
| Support and contact | Public claim only | The terms of use direct questions to agents@informotion.com.au or 1300 474 288, and the site privacy page uses the same contacts for removing a record of a visit. The EncompaaS page states 'We build the systems. A human reads and replies.' No service level, support hours, escalation path or response target is published on any page read. | Provide support hours, response targets and escalation for a fault that puts a statutory clock at risk, and state who supports the EncompaaS layer. | [Reasonable Steps - Terms of use (Informotion Pty Ltd, ABN 41 161 716 007), last updated 2 August 2026](https://reasonablesteps.com.au/terms.html); [Reasonable Steps - website privacy page, last updated 2 August 2026](https://reasonablesteps.com.au/privacy.html); [What is EncompaaS? - vendor explainer for the discovery and classification platform underneath the product](https://reasonablesteps.com.au/encompaas.html) |
| Release stage and references | Not confirmed | No release stage, general-availability date, version or named agency customer for Reasonable Steps is published on any page read, and the terms state every screenshot and the overview video use invented demonstration data not drawn from any customer environment. Informotion's corporate page presents Reasonable Steps alongside its other named products without a customer reference for it. | Is Reasonable Steps generally available, how many agencies run it in production today, and can we speak to a reference agency in our jurisdiction? | [Reasonable Steps - Terms of use (Informotion Pty Ltd, ABN 41 161 716 007), last updated 2 August 2026](https://reasonablesteps.com.au/terms.html); [Reasonable Steps - product site: why it exists, how it works, jurisdictions, architecture and licensing](https://reasonablesteps.com.au/); [Informotion - corporate home page listing Reasonable Steps as an Informotion product](https://informotion.com.au) |
| Task fit and what the officer still does | Public claim only | On the vendor's own documents the product assembles evidence and drafts while the statutory decision stays with the delegated officer: it classifies, proposes grounds and drafts a statement of reasons from what is on the file, records who decided and whether a suggestion was followed, and does not make the decision. The custodian questionnaire and the recorded reason for not searching a system are both officer inputs, and the certificate of search is signed and countersigned by named roles. | On a sample of our matters, how long does an officer spend on the custodian questionnaire, the review queue and the certification steps, and which of those steps cannot be delegated under our instrument? | [Reasonable Steps - Terms of use (Informotion Pty Ltd, ABN 41 161 716 007), last updated 2 August 2026](https://reasonablesteps.com.au/terms.html); [Reasonable Steps - product site: why it exists, how it works, jurisdictions, architecture and licensing](https://reasonablesteps.com.au/) |

## Notes

Phase 2 findings carried forward unchanged, including that no generative or large-language-model component is described anywhere in the vendor's published material and that every AI component named is a third-party Microsoft or EncompaaS service. One addition from the EncompaaS explainer read in this phase: its architecture diagram description names insight providers 'including OpenAI, machine learning, contract extraction and Azure Cognitive Services', which is the only foundation-model provider named anywhere, and it is named for the underlying platform rather than for this product. Binding documents available are thin by design: the terms of use are a short page that defers everything commercial to an unpublished signed agreement, and the site privacy page covers only website visits. There is no security page, no trust centre, no data processing agreement and no subprocessor list in the three-URL site map, so encryption, incidents, transfers, exit, humanAccess, feedbackUse and subprocessors are recorded as not_verified with the question to put to the vendor. Informotion publishes a corporate privacy policy effective 13 August 2026 which addresses retention, deletion within 30 days, international disclosure to cloud providers with servers in the United States, Europe and the United Kingdom, the Notifiable Data Breaches scheme and a statement that it does not currently use automated decision-making that materially assists decisions significantly affecting an individual without meaningful human review; that document was read from a local cache whose source URL could not be confirmed, so it is not cited and nothing in this profile rests on it - the firm should request it directly from the vendor. hostingRegions and australianRegion are recorded as unknown deliberately: the product runs in the customer's own Microsoft tenant, so tenant region is the customer's choice, and no region is published for the EncompaaS service or the Azure AI endpoints, which is not the same as Australian residency being offered. facts.assurance is empty because the IRAP and PROTECTED statements on the product page are about Microsoft Azure and Microsoft 365, and the ISO 27001 statement is about EncompaaS Pty Ltd - none is an assessment of Reasonable Steps. No ACN was published; the ABN is from the terms page. Pricing, release stage, any named agency customer and product-level assurance remain unpublished. Statutory access casework and redaction have no CAPABILITY value, so matter-management and ediscovery-document-review carry them; the gaps are reported to the Maestro. Capability list updated 2026-09-27 when the controlled vocabulary was extended from 19 to 38 values: added redaction. Values already present were kept, because they remain true descriptions of what the product does.

## Sources

- [Reasonable Steps - product site: why it exists, how it works, jurisdictions, architecture and licensing](https://reasonablesteps.com.au/) (checked 2026-09-27)
- [Reasonable Steps - Terms of use (Informotion Pty Ltd, ABN 41 161 716 007), last updated 2 August 2026](https://reasonablesteps.com.au/terms.html) (checked 2026-09-27)
- [Reasonable Steps - website privacy page, last updated 2 August 2026](https://reasonablesteps.com.au/privacy.html) (checked 2026-09-27)
- [What is EncompaaS? - vendor explainer for the discovery and classification platform underneath the product](https://reasonablesteps.com.au/encompaas.html) (checked 2026-09-27)
- [Informotion - corporate home page listing Reasonable Steps as an Informotion product](https://informotion.com.au) (checked 2026-09-27)
- [Reasonable Steps site URL list - firecrawl map of reasonablesteps.com.au returning three URLs (index, encompaas.html, terms.html), used for the absence findings](https://reasonablesteps.com.au) (checked 2026-09-27)

A product profile is research to support questions. It does not approve a product for any firm. Public product information supports questions; it does not approve a product for your firm. Verify the exact plan, settings and signed terms.