1
Define the scope and name the policy owner
Decide whether the policy covers all AI tools or only specific categories (generative AI, automated decision-making, etc.). Assign a named owner β typically the Head of IT, CISO, or Chief Operating Officer β who is accountable for maintaining and enforcing it.
π‘ Scope by capability, not by tool name. 'Any software using machine learning or large language models' ages far better than a list of named products.
2
Audit which AI tools employees are already using
Survey your teams before drafting the acceptable-use section. A shadow IT audit often reveals 5β10 AI tools in active use that IT was unaware of β these inform both the approved list and the prohibited-use rules.
π‘ Check browser extensions and app integrations, not just standalone tools β AI is increasingly embedded in productivity software employees already use daily.
3
Set your data classification rules
Map your existing data classification tiers (public, internal, confidential, restricted) to specific AI permissions. For each tier, state explicitly whether data in that category may be entered into external AI tools and under what conditions.
π‘ If you do not have a formal data classification policy, create a simple two-tier version (shareable vs. non-shareable) as an appendix to the AI policy to unblock this step.
4
Draft the acceptable and prohibited use lists
Write at least four concrete approved use cases and at least four explicit prohibitions. Use specific examples β 'drafting a first-pass sales email for human review' and 'entering a customer's financial records into a public AI tool' β rather than abstract principles.
π‘ Organize acceptable uses by department (marketing, engineering, finance) so employees can quickly find the rules relevant to their own work.
5
Build the approved vendor list
List every AI tool currently approved for use and the data tiers each may process. Include the vendor's data retention period and whether they use prompt data to retrain models. This list lives in Appendix A and is updated as tools are approved or deprecated.
π‘ Check each vendor's DPA (Data Processing Agreement) and sub-processor list before adding them. Many consumer AI tools have no DPA available β that alone is grounds for restriction to public-data-only use.
6
Define the human review requirement
State which output types require human review before use (client deliverables, external communications, hiring decisions) and what 'review' means β not just reading, but verifying facts, checking for bias, and confirming the content meets quality standards.
π‘ For high-stakes outputs like legal documents or financial analysis, require sign-off by someone with domain expertise in the subject matter, not just the employee who generated the output.
7
Set the training and enforcement terms
Specify the training format (live session, e-learning module, or written acknowledgment), the completion deadline for existing employees, and the consequences for violations. Tie the policy acknowledgment to your existing onboarding workflow.
π‘ A signed acknowledgment form β even a simple email confirmation β creates a record that the employee received and read the policy, which matters in any enforcement action.
8
Schedule the first review date before publishing
Set a calendar reminder for the first policy review β six months from publication β before you distribute the document. Include the review date in the policy header so employees know it is current.
π‘ Assign the review to the policy owner in your HR or project management system at the time of publishing, not as an afterthought six months later.