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Company AI policy: five rules for ChatGPT and Copilot

45% of employees already use AI at work and 67% do so on personal accounts. A five-rule policy signed by management brings order before Copilot is switched on.

Updated 13 October 20266 min read

More than 10 workstations · support contract · remote, on-site and phone support

At a glance

For decision-makers short on time.

  • 0145% of workers already use AI at work and 67% with personal accounts (Verizon, 2026).
  • 02Copilot shows whatever permissions allow: review access before switching it on.
  • 03An AI policy fits into five rules on one page, signed by management.
  • 04Since 2 February 2025, the AI Act requires AI literacy from every company.
In this article

A company AI policy costs one meeting and one sheet of A4. Not having one can cost the confidentiality of clients, salaries and contracts. Before letting the team use ChatGPT at scale or switching on Copilot, the board must settle three things: the authorised tools and the account used, the information that always stays out, and who can open what in Microsoft 365. Below we explain the sequence DataRoad applies with its clients and what the AI Act already requires SMEs to comply with.

Are your employees already using AI without authorisation?

Very probably, yes. Verizon's annual Data Breach Investigations Report (2026 edition) shows that 45% of people regularly use AI on work computers, against 15% a year earlier. Worse: 67% sign in to these services with accounts the company does not control.

AI used outside the organisation's control, so-called shadow AI, has become the third most recorded non-malicious internal cause of data leaks. Banning it, therefore, does not work. Without an official alternative, the team uses their phone and personal account, and the company loses track of what goes out.

What data is exposed when a personal account is used?

Everything pasted into the conversation. The examples are mundane: a bank statement sent for summarising, a client's message rewritten by a salesperson, a performance review polished by HR.

What changes everything are the terms of service. On consumer versions, OpenAI may use conversations to train its models unless the user turns that setting off. On business subscriptions and the API, the default is the opposite: content is kept out of training. The line between the two worlds is a business account, administered by the company.

A simple comparison: discussing a deal with AI on a personal account is like negotiating on the phone on a crowded train. With a business account, the conversation moves to a closed room, with house rules and a record of who was present.

Can Copilot reveal confidential files?

It can, if the permissions are already wrong. Microsoft 365 Copilot does not force any door: according to Microsoft's documentation, it only returns information the user can already, at the very least, read. The danger lies in the shares nobody has reviewed.

It is what we regularly find in audits. A board folder open to the whole organisation. A link created three years ago to the payroll spreadsheet, valid for any colleague. A SharePoint site for a closed project, with no restrictions. For years this went unnoticed. With Copilot, a question about the sales team's pay can get an instant answer.

The order is non-negotiable: first clean up access in SharePoint, OneDrive and Teams; then open Copilot to a restricted group. It is about configuring the company's Microsoft 365 properly, not buying more licences.

Which rules should the AI policy contain?

Five are enough. They fit on one page, and it is management that signs, not the engineer.

RuleApplicationWho is responsible
1. A closed list of toolsOnly approved tools, always with company credentials; no private accounts for work matters.Management and IT
2. Prohibited informationNo personal data on clients or staff, clinical information, pay, credentials, contracts or confidential proposals.All users
3. Clean access firstShares and open links reviewed in SharePoint, OneDrive and Teams; Copilot starts with a pilot group.IT
4. Review by a personAI drafts; someone validates figures, names and facts before the document reaches the client.Line managers
5. Training with a recordA short session for the whole team and an attendance sheet kept on file: the proof of the literacy required by law.Human resources

Fold them into the set of internal security policies that any organisation with more than 10 people should have documented.

Checklist before the first pilot

  • Authentication MFA on every account, without exception.
  • Leavers Users who have left deleted and licences returned.
  • Public links "anyone" links audited and switched off wherever possible.
  • Restricted areas Board, HR and finance accessible only to those who need them.
  • Test group 5 to 10 users, with a date set for evaluation.

What does the AI Act require of an SME today?

It requires AI literacy. Regulation (EU) 2024/1689 has been in force since 1 August 2024 and applies in stages. For a company using ChatGPT or Copilot in everyday work, three points matter:

  • Since 2 February 2025 The prohibited practices and Article 4 apply. Anyone using AI must ensure their people are sufficiently prepared to use it with judgement.
  • July 2026 Regulation (EU) 2026/1744, known as the Digital Omnibus on AI, pushed high-risk obligations back to 2 December 2027 (stand-alone systems) and 2 August 2028 (systems embedded in products). Literacy remained mandatory.
  • High risk Covers, for example, candidate selection, biometrics and critical infrastructure. If AI plays a part in recruitment, seek legal advice.

Those who use AI to draft messages, summarise reports or put proposals together do not need certification. They need to show that the team knows the tool, knows where it fails and handles data with care. Rule 5 provides that proof.

DataRoad does not provide legal advice. We carry out the technical side (accounts, access, logs) and help prepare the training session.

How does this work in a company with three offices?

Velv by OnRising produces software in Porto, Lisbon and Rio de Janeiro, with around 200 workstations managed by DataRoad under IT Unlimited. Almost half of its revenue (45%) comes from international clients, and the contract covers firewall, network security and protection policies.

For a team like that, deciding which client information may pass through an AI is routine, and the rule has to be the same in all three cities. The AI policy joins the existing policy pack and is enforced by the same team that manages identities, access and devices.

Where should you start this week?

  1. Ask: find out which AI services the team uses today.
  2. Make it official: choose one tool and give it business accounts.
  3. Audit: have access reviewed before any Copilot test.

Without MFA across the board, that is the priority: it is the starting point of a Zero Trust model adapted to SMEs. And remember that attackers use AI too: it is worth preparing people against phishing and deepfakes.

Frequently asked questions about AI policy

Should we block ChatGPT on the company network?

It is not the best option. A block with no alternative pushes use onto phones and private accounts; it is safer to make a business tool official and list the prohibited data.

Can an employee see through Copilot what they should not?

Only if they already have that access. Copilot merely amplifies badly assigned permissions (folders open to everyone, old links), which is why the access review always comes before activation.

Does a 15-person company also have to comply with AI literacy?

It does. Article 4 of the AI Act has applied since 2 February 2025 to any professional use of AI, regardless of size; written rules, a short session and an attendance record are the sensible minimum, and the legal reading is for your lawyer.

Does using AI safely mean buying licences?

No. The essentials are configuring what the company already pays for (MFA, reviewed access, business accounts on the chosen tools) and only then are Copilot licences justified.

Next step: AI policy and access reviewed in 10 working days

DataRoad audits your Microsoft 365 shares, shows you what Copilot would make visible and delivers the rule sheet ready to sign. Protection is part of the IT Unlimited Premium plan and our complete managed cybersecurity. Request a no-commitment proposal.

More than 10 workstations · support contract · remote, on-site and telephone support. Call +351 211 459 950 * or write to sales@dataroad.pt.

*Call to a Portuguese landline.

Sources consulted

Chosen by respected and international companies

Garcia, GarciaGuestUNMQ DigitalMinistério PúblicoVentaskETISMEGReltio by SAPRestreamVelvEscola Nacional de Saúde PúblicaCircuito EstorilSyoneCreative MindsInstituto Superior TécnicoRTPUniversidade Católica PortoUniversidade Católica PortuguesaFaculdade de Medicina de LisboaUniversidade de LisboaClínica MulherPresidência da RepúblicaESELUpMUN[it]STENEmbajada de España en PortugalNBCC ConsultingInstituto dos Registos e do NotariadoVila GaléBe Poet Baixa HotelBe Hotel LisboaRossio Plaza HotelServiced Apartments Boavista PalaceMitrelliJunta de Freguesia de Massamá e Monte AbraãoInsidepurpleUniveteColégio MinervaPTR Pharma ConsultingInfocapitalHD Duecitânia Design HotelYunit ConsultingMyWindowArqsizeAxiaVestasContinentalGRENKEBaker TillyVINCI AirportsANA Aeroportos de PortugalE.LeclercUriachbeqomNewhotel SoftwareeasyHotelOuro Rossio HotelNicola Rossio HotelClínica LambertBanco do BrasilBoostUphillHole19Ambassade de France au PortugalU.S. Embassy PortugalEmbaixada da Arábia SauditaEmbassy of CyprusPanikeAugusta LabsIGASSISPorta da Frente Christie’sonRisingFresh DesignGesto EnergyBernerQuatenusSegurança SocialCâmara Municipal do MontijoCompany AI policy: five rules for ChatGPT and CopilotCiphraCentury 21Hotel Solar PalmeirasSINCTAAPCTAVarandas de Lisboa★★★★★ 5,0 · 52 Google reviews

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