
The most common question when an organisation starts using AI is a very specific one: can I paste this here? The answer depends on two things: the type of information and the type of tool. With a clear table, most doubts can be resolved without asking anyone.
Three types of tool
- General-purpose tool: a public assistant, or one without a contract with the organisation, such as the free version of a chatbot. There are no guarantees about where the data is processed or whether it is used to train the model. Only public information is allowed.
- Corporate tool under contract: a contracted assistant, with corporate accounts, a data processing agreement, a commitment not to train on the data, processing in the EU and, in the public sector, certification under Spain's National Security Framework (ENS). For example, Microsoft 365 Copilot with a business licence. Internal information is allowed and, under certain conditions, pseudonymised personal data.
- Specific assessed system: a system for a specific use case that has gone through a full assessment (registration record, impact assessment where applicable, security and authorisation). The data provided for in its authorisation is allowed, including personal data and, if approved, sensitive data.
An important nuance: a tool under contract that processes data outside the EU involves an international transfer. It does not allow personal data without appropriate safeguards, an impact assessment and a report from the data protection officer.
The table
| Information | Examples | General-purpose | Corporate under contract | Assessed system |
|---|---|---|---|---|
| Public | Legislation, published information, press releases, open data | Yes | Yes | Yes |
| Internal | Procedures, technical inventories, drafts without personal data | No | Yes | Yes |
| Personal data | Customers, employees, citizens with name or ID number | No | Only pseudonymised and if the use is authorised | Yes, if provided for and assessed |
| Special categories | Health, minors, victims, disciplinary proceedings | No | No | Only with an impact assessment and a favourable report from the DPO |
| Confidential or protected | Bids in a tender, security plans, passwords, privileged legal reports | No | No | No, unless specifically authorised |
Rule of thumb: if you would not email that information to an external person, do not put it into a non-corporate tool.
Quick examples
- Summarising published legislation with a general-purpose assistant: yes.
- Pasting the facilities maintenance sheet to prepare a report: only in the corporate tool.
- Pasting a customer list to look for duplicates: no, except in a system assessed for that purpose.
- Asking for a report based on an employee's health file: no, except in an assessed system with an impact assessment.
- Uploading the bids received in a tender to compare them: no. They are confidential and, in addition, evaluating them is the job of the tender evaluation committee.
Basic rules for AI users
- Use AI as support, never to replace professional judgement or a signature.
- Use only authorised tools, with corporate accounts and organisation devices.
- Never enter credentials or passwords.
- Do not send or sign anything generated with AI without having read it in full.
- Complete the basic training before using it.
- Report any incident or possible data leak immediately.
How to verify what the AI returns
- Check data, figures, dates, names and legal references against the original source: AI can invent articles or court rulings.
- Check that no personal data has slipped in that should not be there, taken from another document.
- Be wary of very confident answers about things the tool cannot know: internal data it has not been given or very recent legislation.
- State, where appropriate, that a document has been prepared with the support of AI.
- Report any incorrect, biased or offensive answer.
What to do if something goes wrong
If a tool shows another person's data, someone enters confidential information where they should not, or the AI follows instructions hidden in a document:
- Stop: stop using it for that task and do not forward the output.
- Preserve the evidence: screenshot, prompt, response, tool, date and time.
- Report it immediately through the incident channel.
- Alert the person in charge if the output has already reached a customer, a citizen or a case file.
Those in charge assess the severity, contain the problem and notify when required: a personal data breach that poses a risk must be reported to the Spanish Data Protection Agency (AEPD) within 72 hours at most.
Questions staff ask
Can I connect the corporate assistant to a folder with confidential information? By default, no. Moreover, with tools such as Microsoft 365 Copilot there is no need to “connect” anything: they can already read everything the person can see. If you have access to ongoing bids, privileged legal reports or security plans, ask for them to be protected with sensitivity labels or excluded from search, and do not ask for summaries based on those documents.
Can I ask it to summarise a case file containing a person's data? With a general-purpose tool, no. With the corporate one, only if that use is authorised and with the minimum data necessary. If it involves health, minors or social services, only in a system assessed for that purpose.
Can I use a free chatbot on my phone to draft a report? No. The rules require authorised tools, corporate accounts and organisation devices. If the report only uses public information, use the authorised general-purpose tool from your work computer.
Can AI reply directly to a complaint? Not directly. It can prepare a draft, but a person reviews it, corrects it and signs it, because the reply has consequences for the complainant.
Can I record a meeting where people are discussed and summarise it with AI? Only under certain conditions: notify participants at the start, use the corporate tool, restrict access to the summary and set how long it will be kept. If health, sanctions or performance reviews are discussed, it is better not to record.
Training by role
No one should use AI without basic training; moreover, the EU AI Act requires AI literacy measures. A simple plan:
| Role | Training | Indicative duration | Content |
|---|---|---|---|
| All staff | Responsible use of AI | 1–2 h | What AI is and its limits, what information can be entered, verification, authorised tools, incidents |
| Users of corporate assistants | Practical day-to-day use | 4 h | Email, documents, presentations, meetings, how to ask well and how to verify |
| Supervisors and managers | Overseeing AI systems | 3–4 h | Automation bias, test benches, incidents, lifecycle |
| Technical, security and data protection staff | Governance and compliance | 6–8 h | Impact assessments, security, agents and permissions, contract clauses |
How to write your own policy
- Inventory the tools already in use, authorised or not. There are usually surprises.
- Classify them into the three types (general-purpose, corporate under contract, assessed system) and check where they process data.
- Adapt the table in this article to your information categories and your real examples.
- Set the basic rules and the incident channel.
- Publish the list of authorised tools and the procedure for requesting a new one.
- Train before you enforce.
- Review it every year or whenever a relevant new tool or regulation appears.
Types of incident worth recognising
- An incorrect answer with consequences: a deadline, a requirement or an amount wrongly stated to a customer or a citizen.
- A biased, discriminatory or offensive answer.
- Data exposure: the tool shows another person's data, or someone has entered personal or confidential information where they should not have.
- Anomalous behaviour: the AI follows instructions hidden in a document or performs actions that were not requested.
- Unauthorised use: a tool that is not on the list or a use outside the approved purpose.
Every incident is logged, its cause analysed and corrected so that it does not happen again: adding the case to the test bench, adjusting a permission or reinforcing training.
The table only works with technical controls
The rules are reinforced with data loss prevention, blocking of unauthorised tools and sensitivity labels. If you are going to roll out Copilot, also read how to prepare the organisation before enabling it.
At Bidatia we help organisations draft and implement AI use policies tailored to each one, with their technical controls and training.
Frequently asked questions
Can I use free ChatGPT with company information?
Only with public information. Free versions, or those used with a personal account, offer no guarantees about where the data is stored or whether it is used to train the model.
Can I put personal data into corporate Copilot?
Only if the use is authorised, with the minimum data necessary and preferably pseudonymised. Health data, data on minors or other special categories require a specifically assessed system.
What happens if someone pastes confidential information into a public AI?
It is an incident: it must be reported immediately, the evidence preserved, and those in charge must assess whether it is a personal data breach that has to be notified to the Spanish Data Protection Agency (AEPD) within 72 hours.
Do I have to state that a document was produced with AI?
Where appropriate, yes. And the EU AI Act requires it to be disclosed for AI-generated text published to inform the public on matters of public interest, unless it has undergone human review and is subject to editorial responsibility.
Is a written policy enough?
No. It works when it is backed by training and technical controls: data loss prevention, blocking of unauthorised tools and sensitivity labels.