CyberSolace / AI governance
Your organisation needs an AI policy. What happens next?
An AI policy should help people use tools confidently and leaders manage the risks. The approach is relevant to many organisations, particularly those looking to establish a practical foundation for AI governance without extensive in-house expertise.

Staff use AI to tidy a newsletter, take meeting notes or review applications. Who knows what information is shared, and who is responsible for the result?
The executive view
Four decisions to make
01
Give staff clear guidance on tools, information and checking outputs.
02
Match controls to the use and its potential consequences.
03
Make human oversight meaningful for decisions and published information.
04
Assign ownership and review tools, feedback and changing risks.
01
What do people need to know before using AI?
A recent CyberSolace engagement highlighted that staff need different guidance from those approving tools and overseeing risk.
Staff guidance can cover approved tools, information boundaries, output checks and where to ask for help. A management framework can cover approvals, supplier checks and review.
Before sharing information, ask who it could identify, whose information it is, where it is going, whether less would do and who will check the output. Removing a name does not necessarily make it anonymous; other details may still identify someone.
Illustrative example
Vague
“Use AI responsibly.”
Illustrative example
More useful
“Use an approved tool for work information; do not enter personal or confidential information unless that use is approved. Check the output before sharing it.”
Key takeaway: People need guidance they can apply before they paste.
02
How much review does each AI use need?
Improving public text differs from ranking applicants, analysing sensitive records or speaking for an organisation. Controls should reflect the information, purpose and possible effects—not the product name alone.
An organisation can distinguish low-risk tasks, routine uses needing an approved tool, higher-impact uses requiring documented review, and uses it will not permit. These are management choices, not a substitute for the EU AI Act’s legal classifications.
Everyday assistance
A task with public information may need guidance and an output check.
Decisions affecting people
Uses influencing recruitment, access or other important outcomes warrant closer review and accountability.
An organisation may prohibit a use because it falls outside its risk appetite, even where there is no blanket legal ban.
Key takeaway: Match the control to the consequences of the use.
03
What should you check before approving a tool?
Existing email, document, meeting or customer-service software may add AI features. A familiar supplier or licence does not establish that a feature is suitable for every purpose.
Check what information the service receives, who can access it, retention and deletion, whether inputs or outputs may develop the service, and the actual account’s contract and settings. If an assistant can act, consider its access to mailboxes, files and other systems.
Record approved purposes, accounts, data limits and settings in a short tools list. The Information Commissioner’s Office guidance discusses accountability and privacy in AI procurement.
Key takeaway: An approved tool still needs boundaries for its approved use.
Explore your organisation’s controls with our AI self-assessment.
04
Who checks the output and makes the decision?
A responsible person needs the authority, time and information to question an AI recommendation. If they cannot inspect its basis or disagree with it, their involvement may offer less assurance than expected.
For significant decisions, establish who decides, what they check and how challenges are handled. Before publication, verify important claims and references: fluent text and plausible citations can be wrong.
Why it matters: A person’s name on a process is only useful if they can exercise judgement.
Know the rules
Where solely automated decisions produce legal or similarly significant effects on people, EU GDPR protections may apply subject to the legislation’s conditions and exceptions. The relevant assessment is fact-specific; a simple “human in the loop” label is not enough to establish what law requires. Read the EU GDPR, including Article 22.
Key takeaway: Human oversight needs the ability to question and correct.
05
Which rules may apply to your AI use?
Data protection rules and the EU AI Act address different questions. The obligations depend on the specific information, system, role and circumstances.
Why it matters: A policy should help identify when a proposed use needs specialist review.
Know the rules
Where personal data is involved, GDPR considerations can include purpose, lawful basis (the legal reason for processing), minimisation (using only necessary data), security, retention, supplier roles and international transfers. A data protection impact assessment is required in the circumstances set out in the law, including where processing is likely to create a high risk to individuals; it is not automatically required for every AI use.
The EU AI Act is a separate framework. Its applicability and obligations depend on factors including geography, the organisation’s role and the AI system’s intended use. As of October 2026, requirements have been introduced in stages and the timetable for some high-risk systems differs from other provisions. The European Commission’s overview explains the scope and timetable.
For relevant providers and deployers, the AI Act also requires measures to support AI literacy, taking account of the people involved and the context of use. That need not mean the same training for every role: a person drafting a public newsletter may need different guidance from a manager overseeing a tool used in an important decision. See the Commission’s AI literacy guidance.
A UK organisation may need to consider UK data protection law and, depending on its circumstances, EU rules as well. Specific obligations should be assessed for the use in question.
This article is general information, not legal advice.
Key takeaway: Check the rules against the actual use and your organisation’s role.
06
How do you keep the policy useful?
As tools change and experiments become routine, start with a named owner, a record of approved uses, a route for questions and incidents, and regular discussion. Review a use when its purpose, data, supplier terms or access changes.
A SHRM article on putting an AI policy into practice highlights ownership, education, feedback and review. It distinguishes adoption from quality, risk and business value: more usage alone does not show whether a tool is delivering worthwhile outcomes safely.
Ask staff what is difficult; unapproved use may indicate that an approved tool does not meet a genuine need. Monitoring should be proportionate and respectful of privacy.
Key takeaway: Ownership and feedback make review possible.
07
What should you discuss first?
Identify what is known, what needs checking and who will act.
- ☐ Where is AI already used, including in existing software?
- ☐ What information can those tools receive, and what happens to it?
- ☐ Which uses could affect people, confidentiality, decisions or reputation?
- ☐ Who approves a new use and remains accountable?
- ☐ What guidance and training do staff and managers need?
- ☐ How can someone report an error or disclosure and get help?
- ☐ When will you review the tools, safeguards and policy?
Key takeaway: A first discussion can identify owners and next steps.
A practical next step
How well do you understand your AI risks?
Our AI System Data Security Self-Assessment explores accountability, data handling, suppliers, monitoring and incident readiness.
It is a starting point, not a compliance determination or a tailored review.
Bring policy and practice together
CyberSolace can help you understand current AI use and develop proportionate policy and governance arrangements. Contact us to discuss your needs.
Sources and further reading
European Union
- European Commission: navigating the AI Act — scope and timetable.
- European Commission: AI literacy questions and answers — literacy measures.
- EU General Data Protection Regulation — data protection requirements.
United Kingdom
- ICO: accountability and governance implications of AI — UK guidance on AI and data protection.
Policy in practice
- SHRM: HR leaders, you have implemented an AI policy—now what? — ownership, measurement and review.
Legal sources and guidance checked 31 October 2026.