The essentials in 30 seconds
- 4 main risks: exposure of sensitive data, factual hallucinations, vendor dependency, and unsupervised usage drift.
- GDPR: Copilot and Gemini are compliant if configured correctly (EU residency + signed DPA + employee notification).
- Usage policy: an essential document to draft before any deployment, defining authorized, restricted and prohibited uses.
- Sensitivity Labels: a technical mechanism to block AI on the most sensitive files.
- Mandatory training: governance without training doesn't work — employees must understand why the rules exist.
The identified risks
Four categories of risk are associated with the use of AI in corporate office work:
An employee submits to AI a document containing personal data (customers, HR) or trade secrets. Even if the data is not used for training, it transits through the vendor's system and may be retained temporarily.
AI generates incorrect figures, dates, names or quotes in official documents or external communications. Without review, these errors can compromise the company's credibility or create legal risks.
All of the company's workflows rely on Copilot or Gemini. An outage, a pricing change or a withdrawal of the service can paralyze productivity if no alternative is planned.
Employees use AI for unsupervised tasks: generating fictitious candidate CVs, circumventing validation processes, creating misleading content or manipulating numerical data.
Governance framework
An effective governance framework for office AI rests on 4 complementary pillars:
Acceptable Use Policy (AUP)
A reference document defining the rules for using office AI in the company. Recommended structure: (A) Authorized and encouraged uses (writing first drafts, rephrasing, summarizing meetings...); (B) Restricted uses requiring validation (externally distributed documents, content involving customer data...); (C) Prohibited uses (processing sensitive personal data, generating misleading content, circumventing validation processes). The AUP must be signed by each user before activating Copilot.
Data classification and protection
Set up Sensitivity Labels in Microsoft Purview (or Google Workspace DLP equivalent) to classify your files: Public, Internal, Confidential, Highly confidential. Configure the policies so that "Confidential" and "Highly confidential" files cannot be processed by Copilot / Gemini. This technical measure doubles the organizational protection of the AUP.
Training in AI critical thinking
Governance without training is ineffective. Train your employees to identify hallucinations (verification of sources, figures), to understand the limits of AI and to apply the rules of the AUP. Target: 2h of mandatory training for every Copilot/Gemini user before the first activation. Refresh the training every year.
Continuous control and audit
Designate an AI referent per department (often a Copilot ambassador) responsible for reporting incidents and drift. Set up a dedicated email address to report problematic uses. Carry out an annual usage audit (review of Copilot logs in Microsoft Purview, interviews with the referents). Contact us to develop your governance framework.
Practical implementation
The 5 priority actions for an operational office AI governance in 30 days:
Draft the Acceptable Use Policy (D1-D7)
Involve the key stakeholders: CIO, HR director, DPO, legal department, a user representative. The AUP must be understandable, practical and non-punitive in tone. It sets clear rules without hindering adoption. Have it validated by the leadership committee before distribution.
Configure data residency (D1-D3)
Verify that your Microsoft 365 tenant is correctly configured for the EU Data Boundary region (organization settings > data residency). For Google Workspace, check the storage region in the admin settings. This configuration is a GDPR prerequisite.
Deploy Sensitivity Labels (D3-D14)
Start by manually labeling your 50 to 100 most sensitive documents (contract templates, HR files, financial data). Then enable automatic labeling based on patterns (SIRET numbers, bank card data, customer names in naming conventions). Microsoft Purview offers predefined classifiers to speed up this step.
Train and communicate (D7-D21)
Organize 2 training sessions of 2h for all users: presentation of the AUP, demo of good and bad uses, Q&A. Create a concise "What can I do with AI?" document in A4 format or a poster to display near the workstations. Appoint a visible AI point of contact for questions.
Set up reporting (D14-D30)
Enable Copilot audit logs in Microsoft Purview. Define alerts for abnormal behavior (unusual volume of requests, access to sensitive files). Plan a monthly usage report for the DPO and the CISO.
Results and benefits
Frequently asked questions
Is the use of Copilot and Gemini GDPR-compliant?
Microsoft 365 Copilot and Google Gemini for Workspace are both GDPR-compliant in their default configuration for European companies, provided you (1) configure data residency in Europe, (2) sign the data processing agreement (DPA) with the vendor, (3) inform employees via an update to the IT tools usage policy.
How to prevent AI from producing incorrect information in official documents?
The fundamental rule is to never use AI to generate factual content without human review. For official documents, AI must be confined to formatting tasks, rephrasing already-verified content, and summarizing reliable source documents. Any factual data generated by AI must be checked and validated by a human before distribution.
What to do if an employee uses AI to process confidential customer data?
The response is twofold: (1) technical — configure Sensitivity Labels to block Copilot processing of files labeled "Confidential"; (2) organizational — explicitly include in your usage policy the categories of data that cannot be submitted to AI. Train managers to raise awareness within their teams.
For tech profiles
Matrix of technical controls for office AI governance:
| Control | Microsoft 365 Copilot | Google Gemini Workspace |
|---|---|---|
| Data residency (EU) | EU Data Boundary — M365 Admin | EU region — Google Admin |
| DPA (data processing agreement) | Microsoft Online Services DPA | Google Workspace DPA |
| Sensitive file classification | Microsoft Purview — Sensitivity Labels | Google DLP — Drive labels (limited) |
| AI blocking on sensitive files | Yes — via Sensitivity Labels + Copilot policy | Partial — Google DLP, less granular |
| Audit logs of AI requests | Microsoft Purview Audit | Google Vault (limited logs for Gemini) |
| Retention of AI conversations | Configurable (0-180 days) — Purview | 30 days by default, configurable |
| EU AI Act compliance | Declared compliant (general use) | Declared compliant (general use) |
The European regulation on artificial intelligence (EU AI Act), which entered into force in August 2024, classifies tools like Copilot and Gemini in the category of limited-risk AI systems for standard office uses (writing, summarizing, translation). The main obligations for companies using these tools: (1) inform employees that they are interacting with an AI system, (2) not use these tools for automated decisions affecting individual rights (HR, credit, insurance) without human safeguards. See our AI governance offering for complete support.