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AI governance 9 min read

Writing an AI policy: from rules on paper to daily practice

A workable AI policy starts from the questions people actually ask: which tools, for what, with which data and what happens if there is no answer 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 know whether policy and practice still match? A policy that answers those eight questions for each tool works when someone opens a tool. A policy that only describes an attitude gets reinterpreted in the corridor, and then it is whoever sounds most confident who decides, not the policy.

01

A policy is only usable when it gives an answer for each 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 one filed away in a folder

On a Tuesday afternoon, a team leader at an insurer gets a question from someone in her team: 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. It says nothing about this tool.

That is when an AI policy either works or does not. Not when it is adopted, but when a specific question comes up 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 tell you whether this particular tool may be used for this particular 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 happens in the organisation looks different: a meeting tool that summarises, a PDF reader with an assistant, a browser extension that rewrites emails. No template takes a position on those, because a template cannot know which tools your people open. Our introduction to shadow AI describes what that use looks like.

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

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?For each tool, the tasks that fit (translation, 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 a rule of thumb for borderline cases
Who assesses a new tool?A role, a deadline and the questions the assessment covers
What does someone do with a tool that has no decision?A procedure: 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?More than an email, which is forgotten within a week; the decision belongs where the tool is opened
How do we know whether policy and practice match?A comparison of the list in the policy with the tools people actually open, 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 up six months later.

For the question of which data may go in, there is no need to invent anything new. Our article on what you can and cannot put in an AI prompt lists what never belongs in a prompt and what usually does. Adopt that list and add examples from your own work.

What do you write about a tool with no decision?

This is where the team leader got stuck. Her policy had only two options, allowed and not allowed, and the transcription tool fitted neither. At that point an employee guesses, 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 goes there, including the ones 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 leader the conversation in the corridor.

The assessment itself is a fixed set of questions for the vendor: where does processing take place, 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. We explain why that gap is so large in a separate article.

The same applies to the meeting tool that records and summarises the call, and to the browser extension that reads the page 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 beyond the chat window. Uploading, recording, reading the page: name them separately, because people will not recognise them as the same decision unprompted.

How does a decision reach people while they 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 because people are unwilling, but because the document is not there at the moment it matters.

The decision works when it appears where the tool is opened. For an allowed tool, nothing happens. For a tool with no decision, a low-key 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, or without that option if the organisation has set it up that way. For a tool marked "Limited use", the condition the organisation set appears, in one sentence.

BeeSensible does this in the browser: the organisation records a decision for each tool, and that decision appears when someone opens the tool, with the approved alternative as the first button. The extension blocks nothing of its own accord and decides nothing. People can continue unless the organisation has chosen "Employee cannot continue"; what happens next is counted without a user ID. The AI tools page explains how that works.

Here is the overview where those decisions are kept, alongside the observed use:

AI register
AllowedUnder reviewNot allowedAll tools
Search by tool, vendor, domain or former name…
1,012 tools
DeepSeek
Critical · 90/100
Not allowed
Otter.aiNew
High · 68/100
No decision yet
Grok
High · 67/100
Not allowed
ChatGPT
High · 62/100
Allowed
Perplexity
Medium · 55/100
No decision yet
HeyGen
Medium · 53/100
No decision yet

Every tool, scored for risk

Over 1,000 AI tools, each scored from Low to Critical. Nothing is approved or blocked until someone decides.

More about AI Governance

What you see here answers the table's question about changes. Nobody has to remember an email. The decision is where it is needed, and it changes when the organisation changes its mind.

How do you know whether policy and practice still match?

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

The policy in the table answers that last question with a comparison: the list in the policy set against the list of what people open. That can be a quarterly survey, or it can be continuous, at organisation level, in counts and with no person linked to a tool. What you want to be able to say is not who did what, but whether the policy still covers the way tools are used. Without that comparison, a policy cannot demonstrate anything; our article on proving that a policy works explains why.

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

So what ends up in the document?

Less than you would think. A list of tools, with a status for each tool and a condition where needed. A short list of data that never goes in, with examples. A procedure 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.

Anything beyond that is an 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 if you are writing an AI policy, write down the eight questions first, answer them for each tool and only then write the document. If you already have a policy, hold it up against the table and check which questions it leaves unanswered. Usually there are three, and usually they are the ones the team leader had.

FAQ

Common questions

What should an AI policy contain?

Answers to specific 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 how quickly, what someone does with a tool that has no decision, how changes are communicated 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 an 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 sets out, tool by tool, what is and is not allowed 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 for each tool, a short list of data that never goes in and a process for new tools fit on two pages. Anything longer has usually grown through explanations of intent, and nobody reads those 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 guessing whether something is allowed.

How do you know the policy is being followed?

By comparing the list in the policy with the tools people actually open 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 from BeeSensible

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