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AI governance 9 min read

Writing an AI policy: from agreements on paper to something that works at the desk

An AI policy that works does not start from a template. It starts from the questions a colleague wants answered on a Tuesday afternoon: which tools, for what, with which data, and what to do when the answer does not exist yet.

Abstract route with nodes through soft shapes
Quick answer

Do not start with a policy document. Start with the questions the policy has to answer: which tools do we allow, for what kind of work, under which conditions, which data may go in, who assesses a new tool, what does someone do with a tool that has not been assessed, how do people hear about a change, and how do we see whether policy and practice still match. A policy that answers those eight questions per tool works at the moment someone opens a tool. A policy that only describes an attitude gets re-explained in the corridor, and then whoever sounds most confident decides, not the policy.

01

A policy is usable only when it gives an answer per tool, not an attitude

02

Eight questions decide what belongs in the policy, and most templates skip three of them

03

No decision yet is a status you write down, not a gap you leave unmentioned

04

A policy written for typing misses the file, the meeting tool and the extension

05

A decision that appears when the tool is opened holds up better than a decision in a folder

A team lead at an insurer gets a question from a colleague on a Tuesday afternoon: can I use this transcription tool for a customer call? The AI policy was adopted last quarter, four pages, reviewed by legal. She looks it up, reads it twice, and still does not know. It says something about handling data carefully and about Copilot being the preferred tool. About this tool it says nothing.

That is the moment an AI policy works or does not. Not when it is adopted, but when a concrete question lands on an ordinary working day. So if you are writing an AI policy, do not start with the document. Start with the questions the document has to answer. If the answers are in there, the policy is usable. If they are not, the question gets answered in the corridor, and then it is not the policy that decides but whoever sounds most confident.

Why not start with the policy document?

Most AI policies begin life as a template. The template describes an attitude: responsible, transparent, in line with the GDPR. All of that is true and none of it helps, because an attitude does not answer whether this one tool may be used for this one customer call.

There is a second problem with the template approach. A template describes the AI use its author had in mind, usually a chatbot someone types text into. The AI use that actually exists in the organisation looks different: a meeting tool that summarises, a PDF reader with an assistant, a browser extension that rewrites emails. No template has a position on those, because the template does not know which tools your people open. What that use looks like is described in what shadow AI is.

So work the other way round. First the questions, then the answers, and only then the document that collects them.

Which questions does an AI policy have to answer?

Eight. They sound simple, and that is the point: someone should be able to act on the answer without asking a second question.

QuestionWhat a usable answer looks like
Which tools do we allow?A list of names with the account type, because ChatGPT on a business account is a different tool from ChatGPT on a free one
For what kind of work?Per tool, the tasks that fit (translating, code, summarising public text) and the tasks that do not (customer correspondence, personnel files)
Under which conditions?One sentence someone can follow: business account only, no personal data, internal use only
Which data may go in?Categories with examples, from a national ID number and a diagnosis to a customer name in an email, plus the rule of thumb for doubtful cases
Who assesses a new tool?A role, a deadline and the questions the assessment asks
What does someone do with a tool that has no decision?A route: where to request the assessment, and what may and may not go into the tool in the meantime
How do people hear about a change?Not only an email, which is forgotten within a week; the decision belongs where the tool is opened
How do we see whether policy and practice match?A comparison of the list in the policy with the tools that are actually opened, in counts, without names

The first four questions appear in almost every policy, even if the answers tend to be too general. The last four are usually missing, and those are exactly the questions that decide whether the policy still holds six months later.

For the question of which data may go in, there is nothing new to invent. A list of what never belongs in a prompt and what usually does is in what you can and cannot put in an AI prompt. Adopt it, and add examples from your own work.

What do you write about a tool with no decision?

This is where the team lead got stuck. Her policy knew two flavours, allowed and not allowed, and the transcription tool fell into neither. What an employee does then is guess, and most people guess in favour of the work that has to get done.

A usable policy gives that situation a name of its own: no decision yet. Every tool that has not been assessed sits there, including the tool nobody has ever asked about. The status comes with an instruction someone can follow immediately: public information only, and this is where you request the assessment. It is neither a ban nor an approval. It is the truth, written down, and it saves the team lead the conversation in the corridor.

The assessment itself is a fixed set of questions for the vendor: where does processing run, what is retained, is input used for training, who are the sub-processors. Record the answers with a date, because AI services change their terms faster than any review cycle.

Why does a policy written for typing miss the file?

Almost every AI policy is written for the prompt: do not type customer names, do not paste account numbers. Almost none says anything about the report someone uploads in one go, even though a single attachment holds more personal data than a month of prompts. Why that gap is so large is covered in your AI policy covers what people type, what about the file they attach?.

The same applies to the meeting tool that records and summarises the call, and to the extension that reads along in the browser to rewrite an email. Nobody types a prompt there, and yet text leaves the organisation. A policy written for typing misses that, and the person using the tool does not see it as AI use because there is no chat window.

So the question "for what kind of work" in the table has to reach past the chat window. Uploading, recording, reading along: name them separately, because people do not recognise them as the same decision on their own.

How does a decision reach the moment of work?

A policy document sits in a folder. The tool sits in the browser. An employee reads the policy once and opens the tool hundreds of times. That difference explains why a policy that is right on paper still does not get followed: not out of unwillingness, but because the document does not show up at the moment it matters.

The decision works when it appears where the tool is opened. For a tool that is allowed, nothing happens. For a tool with no decision, a calm notice appears: public information only, with a button to continue. For a tool that is not allowed, the approved alternative appears as the first button, with the option to continue anyway. For a tool with limited use, the condition the organisation wrote itself appears, in one sentence.

BeeSensible does this in the browser: the organisation records a decision per tool, and that decision appears when someone opens the tool, with the approved alternative as the first button. The extension blocks nothing and decides nothing; continuing is always possible, and what happens next is counted without a user id. How that works is on the AI tools page.

This is the overview those decisions live in, next to the use that has been observed:

Search tool, vendor or categoryโ€ฆ
865 tools
ChatGPT๐Ÿ‡บ๐Ÿ‡ธ
HighAllowed
Claude๐Ÿ‡บ๐Ÿ‡ธ
MediumAllowed
DeepSeek๐Ÿ‡จ๐Ÿ‡ณnew
CriticalNot allowed
Perplexity๐Ÿ‡บ๐Ÿ‡ธnew
MediumNo decision yet
Mistral๐Ÿ‡ซ๐Ÿ‡ท
LowNo decision yet
Midjourney๐Ÿ‡บ๐Ÿ‡ธ
MediumNo decision yet

Every tool, scored for risk

865 AI tools, each scored Low to Critical, with nothing pre-approved or pre-blocked until someone decides.

More about AI Tools

What you see here is the table's question about changes, answered. Nobody has to remember an email. The decision sits where it is needed and changes along when the organisation decides otherwise.

How do you see whether policy and practice still match?

A municipality allows Microsoft Copilot and writes that into its policy. In an inventory six months later, Perplexity, ChatGPT and three specialised tools turn out to be in use alongside Copilot, two of which appear nowhere in the register. That is not an incident. It shows that a one-off inventory is behind as soon as it is finished, and that the question "which tools do we allow" only makes sense if you also know which tools there are.

The policy in the table answers that last question with a comparison: the list in the policy next to the list of what gets opened. That can be a quarterly survey, and it can be continuous, at organisation level, in counts and with no person attached to a tool. What you want to be able to say is not who did what, but whether the policy still covers the use. Why a policy without that comparison cannot demonstrate anything is in you have an AI policy, but can you prove it works?.

This is where the policy meets the law. The GDPR requires in Article 5(2) that you can demonstrate compliance with its principles, and the AI Act expects in Article 4 that organisations work on the AI literacy of the people who use AI systems. Neither prescribes a document called AI policy. What they do ask for can be substantiated with the answers from the table: a decision per tool, a reason per decision, and a comparison with practice. What the GDPR asks beyond that during a rollout, from legal basis to DPIA, is in GDPR and AI tools at work.

So what ends up in the document?

Less than you would think. A list of tools, with a status per tool and a condition where needed. A short list of data that never goes in, with examples. A route for tools without a decision. A name and a deadline for the assessment. And one sentence on how the organisation checks that the list still holds.

Everything on top of that is explanation of intent. That explanation is useful in a training session and in the conversation with the works council, but not in the document someone opens on a Tuesday afternoon to find an answer. Keep the two apart. The other articles on this subject are collected under AI governance.

So whoever writes an AI policy first writes down the eight questions and answers them per tool, and only then the document. And whoever already has a policy puts it next to the table and checks which questions it does not answer. Usually that is three, and usually they are the ones the team lead had.

FAQ

Common questions

What should an AI policy contain?

Answers to concrete questions: which tools are allowed and with which account, for which tasks, under which conditions, which data must stay out, who assesses a new tool and within what time, what someone does with a tool that has no decision, how changes are shared, and how the organisation checks that practice follows policy. An attitude such as responsible or careful is not an answer.

Is an AI policy mandatory?

No law prescribes a document called AI policy. The GDPR does require you to demonstrate how you handle personal data, and the AI Act expects organisations to work on the AI literacy of the people who use AI systems. A policy that says per tool what is allowed and what is not is the practical way to substantiate both.

How long should an AI policy be?

As short as the answers allow. A list of tools, a status and a condition per tool, a short list of data that never goes in, and a route for new tools fit on two pages. Anything longer usually grows through explanation of intent, and nobody reads that at the moment it matters.

What do you do with a tool that has not been assessed?

Give it a status of its own, no decision yet, and say what that means: public information only, and a place to request the assessment. That is more honest than pretending the tool does not exist, and it stops people from guessing whether something is allowed.

How do you know the policy is being followed?

By putting the list from the policy next to the tools that are actually opened in the organisation. That can be a periodic survey, or continuous observation at organisation level, in counts and without a user id. The difference between the two lists is the policy's backlog.

Portrait of Rens Timmermans of BeeSensible

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