A caseworker in the benefits department has to rewrite a letter about a repayment in plain language. The letter is legally correct and unreadable. She opens ChatGPT, pastes in the whole letter and within a minute has a version the recipient will understand. At the top of the letter were a name, an address, a citizen service number and the amount.
The task was fine. The personal data did not need to be there. That is the whole answer: in a municipality the task can usually go into an AI tool, but the data about the resident cannot. What exactly has to come out depends on what you are doing.
Why does this matter more in a municipality?
Because the text you handle on an ordinary day is almost always about someone. A benefit, an objection, a report to the neighbourhood team, an application for a parking permit. Some of it is special-category or highly sensitive: health, debts, a family situation in youth care. And the citizen service number (BSN) appears on nearly every document the municipality sends.
The Dutch Data Protection Authority received several breach notifications in which employees had put personal data into an AI chatbot, and advises organisations to set clear rules on whether this is allowed and with which data. A municipality also has the BIO, the baseline information security standard for Dutch government, which calls for classification and careful handling of residents' data. What that means for AI use is covered in our piece on AI under the BIO and NEN 7510.
This is not about you being the weak spot. You use the tool because it makes the letter better. The only question is what goes into the tool along with it.
Which ChatGPT are you actually using?
There is no single ChatGPT. A free personal account runs under consumer terms: the input can be used to improve the model unless you switch that off yourself, and the municipality has no data processing agreement covering it. OpenAI states on its enterprise privacy page that its business environments do not use input for training by default. That is a different product with different terms, even though the screen looks the same. The difference is explained in free versus business AI accounts.
Which version you may use is for your municipality to decide. Many municipalities have allowed Copilot and not yet decided anything about ChatGPT. "No decision yet" does not mean it is allowed; it means nobody has looked at it. Until somebody does, no text with personal data should go in.
In municipalities that work with BeeSensible, the municipality's decision appears in the browser when you open an AI tool: allowed, limited use with a condition, no decision yet or not allowed with the alternative named. Usually you can carry on; only for a tool that is not allowed may your municipality have set things up so that you cannot continue.