On a Friday afternoon, a neighbourhood team worker has held three "kitchen-table conversations", the home visits where a family's support needs are discussed, and wants to turn her notes into reports before the weekend. She knows a tool that does it in a minute. The municipal executive adopted the AI policy last year: six pages, with the words "careful" and "responsible" in it and Copilot as the preferred tool. About this tool, and about notes from a conversation in a family's home, it says nothing.
This is the moment an AI policy either works or does not. A municipal policy need not be long, but it has to answer her question: may I use this tool, with these notes, and if not, what do I do instead? The general structure of such a policy is covered in our guide to writing an AI policy. This piece is about what is different for a municipality.
Which questions must a municipality's policy answer?
The same questions as anywhere else, with answers that fit municipal work.
| Question | What a municipality writes down |
|---|---|
| Which tools are allowed, with which account? | A list of names with the account type attached; Copilot inside the municipality's own tenant is a different thing from a free chatbot on a private account |
| Which data never goes in? | BSNs, benefits and income data, anything from youth care and social care, objection and enforcement files, confidential papers |
| What applies when dealing with residents? | A chatbot says it is AI; a letter or a formal decision remains the municipality's decision, taken and signed by an employee |
| Who assesses a new tool, and how fast? | An owner in the department that will use it answers the questions, and the DPO and the CISO review it within a set deadline |
| What do you do with a tool without a decision? | Public information only, and this is where you request the assessment |
| How do the front desk and the neighbourhood teams hear about a change? | Where the tool is opened, not in an email from three weeks ago |
| How do we see whether the policy is followed? | The list from the policy set against the tools actually opened, in numbers, without names |
In a municipality the second row is longer than at most companies, and that is no reason to shorten it. A front desk employee has to see at a glance that a benefits case number belongs in the same category as a BSN. A general list is in our article on what you can and cannot share with AI; add examples from your own work, because nobody spots "social services data" in an objection letter about a parking fine.
What do you write down about dealing with residents?
Three things, all short.
A chatbot on the website or on the phone makes clear that it is AI. Article 50 of the AI Act has required that since 2 August 2026, and it is also simple courtesy to a resident asking about their application.
A letter rewritten with help from AI is still a letter from the municipality. Whoever sends it reads it and stands behind it. For a formal decision, an objection or a service, that applies twice over: the decision belongs to the municipality and is taken by an employee, and AI at most helps with the wording. How a municipality handles AI that assesses or prioritises applications is a separate chapter, involving the AI Act and the Algorithm Register; it is covered in our article on AI governance for municipalities.
And residents' data does not go into a tool without a decision, not even to tidy up a letter. Rewriting works with placeholders. The task still gets done, and the resident's details stay within the municipality.
What is the role of the DPO and the CISO?
A different one from the role they are often given. In many municipalities the AI policy ends up with the data protection officer (DPO), because it is about personal data. That clashes with the DPO's position: the DPO reviews and advises, and must be able to do so independently. A DPO who adopts the policy and approves the tools can no longer independently say that something is wrong.
This division works better. The DPO reviews a new tool against the GDPR: legal basis, purpose limitation, data processing agreement, whether a DPIA is needed. The CISO reviews against the BIO, the baseline information security standard for Dutch government: classification of the data, the vendor, where processing takes place. The decision itself belongs to the municipality, in practice the directors or the management team, and each tool has an owner in the department that uses it: the team lead of the contact centre for the translation tool, the manager of the youth team for the transcription tool. That owner answers the questions and moves the review along. And the works council should be involved early, certainly once the policy says anything about how the municipality will measure use.
The register where those decisions are recorded, and how it relates to the Algorithm Register, is covered in our article on the AI register for municipalities.
How does the policy reach the front desk and the neighbourhood teams?
Not through the document. A six-page policy is read once, on the day of the training, and the tool is opened hundreds of times afterwards. What does stick is one line per situation, at the moment that situation arises. How to write that without burying people in rules is explained in our article on communicating AI policy.
Back to the neighbourhood team worker. She opens the tool and sees a short notice, which the municipality has switched on for tools without a decision: no decision has been taken on this tool yet, do not share personal data or confidential information here. She writes up the reports in Copilot that afternoon, without the families' names, and requests the assessment. Two weeks later the municipality has decided: limited use, only for internal meetings without case material, with Copilot as the tool for anything involving residents. From then on, everyone who opens the tool sees that one sentence.
That is not a complicated set-up. It is the list from the first row of the table, with one of four statuses per tool, visible where the work happens.
BeeSensible does this in the browser: the municipality records a decision on each tool from the Inbox, and that decision appears when someone opens the tool, with the approved alternative as the first button. The extension does not block anything by itself and does not decide on the municipality's behalf. For a tool that is not allowed, the municipality decides whether staff can continue after the notice, and what happens next is counted without a user ID.
