Plagiarism and AI at Waterloo: the US server and your alternative

The short answer

Every course outline at Waterloo has to tell you that your work would be stored on a server in the United States, and that you can ask for a different way to be assessed. That requirement has been in force since Spring 2018 and applies whether or not your instructor actually uses the software.

Waterloo is also the only university we have found anywhere that publishes a dated end to Turnitin’s AI detection.

The statement in every course outline

Instructors are given wording they must include. Note the parenthesis — it applies universally, not just where the tool is used:

“As of Spring 2018, all course outlines must include the following boilerplate statement (whether you intend to use the software or not): Turnitin.com: Text matching software may be used to screen assignments in this course. […] Students’ submissions are stored on a U.S. server, therefore students must be given an alternative (e.g., scaffolded assignment or annotated bibliography), if they are concerned about their privacy and/or security. Students will be given due notice, in the first week of the term and/or at the time assignment details are provided, about arrangements and alternatives for the use of Turnitin in this course.”

And the obligation is restated in the university’s own voice: “You must provide students with an alternative to Turnitin. Because students’ submissions are stored on a U.S. server you must give students an alternative […] in order to protect their privacy and security.”

The published alternatives are ordinary academic work — a scaffolded assignment, or an annotated bibliography. You are not being asked to do something exotic; you are being asked to show your working.

California, and the statute it names

The student-facing version goes further than any other institution we have read. It names the location and the law:

“Submitted files are housed on the Turnitin® server based in California, and these files are subject to the USA PATRIOT ACT, 2001. Therefore, if you have concerns about your privacy and or security, you may opt out of using this software and choose another alternative with your instructor. If you do not wish to use this software, please contact your instructor as soon as possible, and discuss an alternative within the first week of the term.”

There is also a detail about where your work ends up:

“In addition to residing on the U.S. server, files are kept on a local D2L server, and your submissions are added to a private pool of UWaterloo documents, but they are not accessible to others as part the general Turnitin database.”

That is meaningfully better than the default at many universities, where submissions join the global comparison database. At Waterloo your essay is compared against Waterloo work, not offered up to every other subscriber.

One thing Waterloo does notdo is cite Ontario’s freedom-of-information legislation by name. The opt-out is grounded in privacy and security generally. That does not weaken the right — it is published as a condition of use — but if you want the statutory basis, you will have to ask.

The wider lesson holds well beyond Waterloo: before you put a draft into any online service, find out where it is stored and whether it is kept. For what it is worth, our own check does not add your text to any third-party comparison database.

What happened to AI detection

The same sentence appears on three separate Waterloo pages, which is usually a sign an institution wants it seen:

“Update: Effective September 2025, AI detection functionality in Turnitin will no longer be available.”

We will report exactly what that says and nothing more. It states that the functionality is gone. It does notsay who decided, or on what grounds. Anyone telling you Waterloo’s reasoning is filling in a blank the university left empty.

What Waterloo did publish, alongside the notice, is its reading of the tool while it existed: the indicator “may be able to highlight some text that might have been generated by AI tools”, but “it is not foolproof”, and it “should not be the only source of evidence used to determine if text was generated by AI”. It also noted that “only instructors and administrators are able to see the indicator” — students never could.

The instruction to staff is the part worth carrying with you: “We recommend that instructors focus on evidence of learning rather than focusing on finding misuse of artificial intelligence.” And to everyone: “Instructors, students and staff should use GenAI transparently.”

On the similarity side, Waterloo says something we wish more universities would: “Note that there is no ‘safe’ colour or percentage. No percentage or colour in the report can fully evaluate whether text has been plagiarized.” If you have been chasing a number, that is your answer — and what a Turnitin score actually means explains why. The same caution applies to our own tool: our published error rates are measured on English and German corpora, and no detector produces proof.

A 1989 policy meeting a 2026 problem

Policy 71 – Student Discipline was established on 6 June 1989 and last updated in 2019 and 2020. It does not define plagiarism, it does not define cheating, and it never mentions artificial intelligence. What it does is list offence categories and warn that the list is illustrative: “Offences listed below are intended to be interpreted broadly. The list is not meant to be comprehensive.”

AI arrives through one line in that list — and the wording matters more than anything else on this page:

“unauthorized aids or assistance as defined by the course instructor”

The instructor is the definitional authority. Not Policy 71, not a university-wide AI charter, not what your friends in another faculty were told. The Office of Academic Integrity spelled out the consequence: “A student who does not comply with the instructor’s rules about the use of such tools will be subject to Policy 71 and an investigation into academic misconduct.”

Which is why Waterloo puts the burden on staff to be explicit: “it’s important for instructors to be explicit about whether artificial intelligence or tools like ChatGPT are allowed […] and if so, the extent to which it is allowed, and if it should be cited and how to cite it.” If your outline is silent, ask — and keep the reply.

Waterloo publishes a sample disclosure sentence you can adapt: “This [text, image, or video] was produced by the author using assistance from [insert generative AI provider]. The author affirms that they have thoroughly examined, modified, and refined the initial AI-generated draft and acknowledges that they are accountable for the content of this assignment.” Our AI disclosure statement guide covers what else a good one contains.

On data, there is a separate warning: “Microsoft Copilot should be used through your UWaterloo account in order to protect the privacy and security of the data that you enter. Be sure not to share any personal, institutional or research data in a GenAI tool that saves and uses your prompt data!”

When you may check your own work

Waterloo is unusually precise here, and the rules differ by what you are writing.

Course assignments, via Turnitin:only if your instructor builds it in. Waterloo publishes the recommended design — one draft submission and one final; the draft is not graded; and the key line, “the similarity report for the draft assignment will not be reviewed by the instructor or TA: it is for the student’s use only.” If your course offers this, use it early, so you have time to act on what it shows.

One warning attached to that dropbox: “Only content related to the course may be submitted […] Unauthorized submissions will be treated as a breach of academic integrity.” Do not park another course’s essay there.

Theses and manuscripts, via iThenticate: genuinely self-service. “Graduate students are encouraged to use iThenticate® to review their research milestones, including theses and research proposals and discuss the results with their supervisors before formally submitting these works.” Undergraduates can request an account for a thesis, essay or manuscript intended for publication.

But not for coursework: “iThenticate is not to be used to check papers or essays to be submitted as a course assignment. It is not to be used by instructors to check student course assignments.”

And there is a strict authorship rule with a published enforcement ladder: you must be the author or co-author, you may not submit work created by your students or manuscripts you are reviewing, and violating the terms brings a one-month account suspension, with a second violation disabling the account permanently. Note the mirror image of Toronto’s rule: at Waterloo a supervisor may notrun a student’s thesis through it at all.

Penalties, and the UR notation

The floor is fixed: “At the conclusion of an investigation where misconduct has been found, the student will be given at a minimum a letter of reprimand.”

Above that, Policy 71 lists disciplinary probation; a grade penalty on an assignment, test, examination or course, or failed standing in a term; failed work term; extra academic work; removal of privileges; additional courses; community service; suspension; expulsion; and “revocation of degree, diploma, certificate, standing or credit”.

Two consequences bite immediately, before anything is decided. From the moment an allegation is reported: “No degree, diploma or certificate shall be awarded, nor shall a student be allowed to withdraw from a course in which an offence is alleged to have been committed […] until the final disposition of the matter.” And a temporary notation goes on your record:

“The associate dean may instruct the Registrar’s […] Office to insert a UR notation (under review)for the course in the student’s academic record. […] If an allegation is made after a student has withdrawn from a course, the withdrawal shall be void, the student re-enrolled in the course and a UR recorded. A UR remains until the matter is dealt with and the appeal period has expired. A student cannot graduate with a UR on his/her record.”

So dropping the course does not end it — the withdrawal is voided and you are put back in. If you are near graduation, a UR is the practical problem long before any penalty is.

Policy 71’s penalty list contains no permanent transcript notation, and no duration for one is stated in the policy text. We are not going to supply a number nobody published.

Aggravating and mitigating factors are enumerated: severity, the weight of the assignment, your level of academic experience, admission of guilt, extenuating circumstances, prior record, and for graduate students whether the work was “one of the major milestones of the graduate program”. Admitting it early is explicitly a mitigating factor.

Who decides, and how fast

Not your instructor, and not a tribunal: “Authority to deal with matters under this policy rests with the undergraduate and graduate associate deans.”

Your instructor may try to settle it informally, but the cap is published: the proposed resolution “may not have a penalty that exceeds a reduction in course grade and disciplinary probation”, it requires your admission of guilt andthe associate dean’s approval — and if the dean rejects it, “the student’s admission of guilt will be void”. That last clause is a genuine protection: an admission offered for a deal does not survive the deal falling through.

The clock: “an associate dean will render a decision within 50 working days from the reporting of the offence.”

Policy 71 sets out what you are entitled to, and the list is worth knowing: a presumption of innocence “unless the contrary is established”; to be made aware of the case against you; to be accompanied by a support person at any meeting or hearing; to have the matter heard by people “not sitting in judgment of their own actions or decisions”; to “know, respond to and seek clarification of evidence presented by witnesses”; and decisions “based on the balance of probabilities with consideration given to consistency and University precedent”.

That last clause is unusual — Waterloo builds precedent into the standard, so like cases are meant to be treated alike. It is a reasonable thing to raise if your proposed penalty looks out of step.

Appeals run to the University Committee on Student Appeals under Policy 72, and the window is short: 10 days from notification. That is the tightest deadline of any institution in this series, so diarise it the day you receive a decision. Most penalties are paused during an appeal — “Penalties (other than removal of privileges and expulsion) are normally not in force while an appeal is being decided.”

Policy 71 requires that “a summary of cases is to be posted to the Secretariat website annually”. We were not able to locate those summaries, so we are not quoting counts.

One caveat about everything above: Waterloo’s Office of Academic Integrity — which published the Turnitin and AI material quoted here — has closed, and its site content is stated to be retained only “for Winter 2026”. If you need to rely on one of these pages, save a copy now.

Before you submit

• Read the Turnitin paragraph in your course outline. It is there by requirement, and it contains your alternative.
• Raise an opt-out in week one. The guidance asks for it within the first week of term.
• Ask your instructor what AI use is permitted. Policy 71 makes them the definitional authority.
• Use the draft dropbox if your course has one, and submit early enough to act on the report.
• Do not try to withdraw from a course under allegation. The withdrawal is voided and a UR is recorded.
• If a decision goes against you, note the 10-day appeal window. It is very short.

If you want a read on your own text before you hand it in, our AI check is free up to 1,500 words, with no account and no name. Our published error rates are measured on English and German corpora, and no detector — ours included — produces proof.

Sources

• University of Waterloo: Policy 71 – Student Discipline — established 6 June 1989; last updated 1 May 2019 and 28 February 2020.
• University of Waterloo: Turnitin and iThenticate — information for students — the US server, the PATRIOT Act statement, and the AI-detection notice.
• University of Waterloo: Artificial intelligence and ChatGPT.
• University of Waterloo: Policy 72 – Student Appeals.

This page is orientation, not legal advice. What binds you is your course outline and Policy 71. Note that the academic-integrity pages quoted here are slated for retention only through Winter 2026.