An AI policy for staff in a small business
A one-page AI policy a small team will read: tools, limits, checks and who to ask.
Privacy, accessibility and AI rules
Your team is probably using ChatGPT already. The risk is less the tool than the account it runs on and what goes into it. This guide sets out what staff can paste, what each plan does with it and where the GDPR and HIPAA lines sit, for a business of 5 to 20 people.
Updated 29 October 2026, about 8 minutes to read
The short answer
Safe enough for text that names nobody. Customer names, contact details and order history belong only in a business plan that does not use your content to improve the product and comes with a data processing agreement. Health information also needs a plan covered by a HIPAA business associate agreement. Card numbers, passwords and ID numbers never go in. On a personal plan, assume whatever you paste is kept.
It depends on two things: the account and the text. The same ChatGPT window behaves differently on a personal Plus account and in a ChatGPT Business workspace. And a draft that says "a customer wants to move her appointment" carries none of the risk of one that says "Sarah Jones, 14 Mill Lane, wants to move her root canal".
So the rule for a small team is short. Use a business account for work. Strip identifying details by default. Keep a short list of things that never go in, whatever the account. The rest of this guide explains why, plan by plan.
Plans and settings change. Everything below comes from the vendors' own help pages as of October 2026. This is general information, not legal advice.
Each of the big three assistants comes in a personal version and a work version, on different terms:
The work versions come with a business agreement under which the provider handles your data for you, and by default they do not use your content to improve their products. The personal versions run under consumer terms that the individual accepted, not your business. A member of staff using their own ChatGPT account on a work laptop is on a personal account, whatever the laptop.
On a personal plan, assume anything you paste is kept, and may be used to improve the product unless someone has changed the settings.
On personal plans:
On ChatGPT Business, Enterprise and Edu, content is not used to improve the models by default. Workspace admins control how long data is kept, and on Business they can view, export and delete members' conversations. A data processing agreement is available for Business and Enterprise. Business is sold to teams of two users or more.
Google says plainly that human reviewers read some conversations on personal Gemini accounts, and asks people not to enter confidential information they would not want a reviewer to see. With the setting called Keep Activity on, chats are saved, auto-deleted after 18 months by default, and used to improve Google's services, including its AI. With it off, chats are still kept for 72 hours. Chats that reviewers have looked at are kept for up to three years.
With a Google Workspace account, Google says chats in the Gemini app are not reviewed by humans and are not used to improve its AI outside your organisation without permission. They fall under your Workspace agreement and its data processing terms.
Microsoft says Copilot and Copilot Chat used with a work account come with its enterprise data protection: they are covered by its business data protection terms, with Microsoft as your processor, and prompts and responses are not used to train its foundation models. The personal Copilot app runs under Microsoft's consumer terms and settings.
This is the choice most small businesses face, so here it is side by side:
Our view: if anyone on the team will paste anything about a customer, the decision is made, and it is Business or the work plan from Google or Microsoft that you already use for email. Plus is fine for an owner working alone, on text that names nobody, with the improvement setting turned off.
A three-colour list is easy to remember and fits on one page:
If a task needs red information, it needs a tool built for that job, with the right agreement, access rules and someone checking the results, not a general chat window. Our AI assistants are built that way: agreed access, rules on data, and a person checking anything that matters before it is saved or sent.
Most drafting jobs do not need the customer's identity at all. Before you paste, take out:
An accountant's example. Instead of pasting the client's email, paste this: "[Client], a sole trader, missed the filing deadline because of illness and asks whether we can help with the penalty. Draft a kind reply asking for the penalty notice and saying a partner will call this week." The draft comes out just as good, and nothing in it identifies anyone.
Swapping a name for initials is not enough. Under the GDPR, information that can still be linked to a person with other details is personal data. If the rest of the message points to one customer, treat it as amber.
When staff paste customer details into an AI tool for work, your business decides what happens to that data and the tool's provider handles it for you. In GDPR terms you are the controller and the provider is your processor. The GDPR expects three things:
Two more points. Health data and the other special categories need a specific legal basis under Article 9, so keep them out of general AI tools. And your privacy notice should mention the kinds of tools that process customer data for you, which our guide to what a privacy policy needs covers.
If HIPAA covers your practice, protected health information may go only into a product covered by a business associate agreement with its provider. As of October 2026:
Even with a BAA, send only the minimum the task needs. Most drafting jobs need none: "a patient asks how to prepare for a first physiotherapy appointment" names nobody. HIPAA and AI chatbots covers the patient-facing side.
Lawyers, accountants and financial advisers usually owe confidentiality to clients under their own professional rules, on top of data protection law. Those rules do not change because the tool is new.
For US law firms, the ABA's Formal Opinion 512 applies the duty of confidentiality to generative AI tools directly, and a firm should read it before client files go near a chat window: see law firm chatbots and ABA Opinion 512. Other professions have their own bodies and rules, so check yours before you set the green, amber and red lists.
It happens. Act the same day:
No blame for the person who tells you. A team that hides mistakes is a bigger risk than one bad paste.
If your team keeps pasting the same documents into chat tools, such as procedures, price lists or policies, an AI assistant for your documents answers from those files with agreed access and shows the source of each answer.
On personal plans, regular chats stay in your history until you delete them, and deleted chats are scheduled for permanent deletion within 30 days unless the company must keep them for legal or security reasons. Temporary chats skip your history but may be kept for up to 30 days. On Business and Enterprise workspaces, your admins set how long data is kept.
No tool is compliant on its own, because compliance depends on how you use it. ChatGPT Business gives you the pieces a business needs: a data processing agreement, no use of your content to improve the models by default, and admin control over retention. You still need a lawful purpose, a line in your privacy notice and rules for staff about what goes in.
Not fully. Turning off "Improve the model for everyone" stops new chats being used to improve the models, but they are still stored in your history, and rating a reply can still share the conversation. Temporary chat goes further, but a copy is kept for up to 30 days. Neither turns a personal account into a business one with a processor contract.
It depends on the account more than the brand. Copilot used with a work Microsoft 365 account comes with Microsoft's enterprise data protection, and ChatGPT Business comes with its own business terms. Both personal versions run on consumer terms. The safer choice is whichever work plan your team will actually use, set up properly, instead of a mix of personal accounts.
Only if nothing else in it points to them. Take out the email address, phone number, street address, order number and any detail that identifies someone on its own. Under the GDPR, information that can still be linked to a person is personal data, so a lightly edited email belongs on a business account, if anywhere.
Yes, signed in to the work account, not a personal one. When you are signed in, the data settings apply across web and mobile. The risk on phones is haste: someone pastes a customer's message while out on a job. Make the work account the one that is already signed in, and put the never list where people will see it.