Guide AI

AI Inventory, Risk Classification and Acceptable Use Policy

How to find every AI tool in use, classify each one by risk, and write an acceptable use policy staff will follow.

10 November 2026
8 min read

This page covers steps 1 to 3 of our AI governance framework, which also sets out who should own AI governance, a plan for the first 90 days and a minimum version for SMEs. Steps 4 to 6 are in AI data protection, human oversight and security controls.

Step 1: Map what you are already using

Before writing a policy, find out what AI tools are in use. Most organisations find more than expected when they look properly.

Four categories to check

🤖
Standalone generative AI tools
ChatGPT, Claude, Gemini, Perplexity, and similar tools accessed directly by staff, often through personal accounts. These are the most common source of data leakage because staff paste content without considering where it goes. Check which accounts are personal free-tier versus business accounts with a data processing agreement in place.
⚙️
AI embedded in tools you already pay for
Microsoft 365 Copilot, Google Workspace AI features, Salesforce Einstein, HubSpot AI, Zendesk AI, and similar. These are often enabled by default or activated by an administrator without a governance conversation. Review your SaaS portfolio and check which AI features are active and what data they access.
🧩
AI in business processes and decisions
Recruitment screening tools, fraud detection systems, insurance pricing engines, and credit assessment tools. These are often the highest-risk category under UK GDPR because they directly influence decisions about individuals. They may have been in place for years without a formal review.
🔌
Browser extensions and productivity tools
Grammarly, Otter.ai, Fireflies, and similar tools that process emails, documents, and meeting recordings. Often installed individually by staff. These can transmit significant volumes of sensitive business content to third-party servers before anyone asks where the data goes.

Survey department heads and run a discovery pass across your SaaS estate. The shadow AI risks guide covers the discovery process in more detail. The inventory becomes your control baseline: every tool on it either has a governance record or gets one before it stays approved.

AI tool register: minimum fields

Record each AI tool in a central register. This becomes the living record that your AI governance owner maintains and your auditors or regulators can inspect.

Field Example
AI tool Microsoft 365 Copilot
Business owner Head of Marketing
Purpose Content drafting, email summarisation
Data processed Internal business data, employee emails
Personal data involved Yes
Vendor Microsoft
Data processing / hosting location UK / EU
DPA in place Yes, via Microsoft Data Processing Agreement
Risk level Medium
DPIA required Yes, completed 24 Aug 2026
Article 22 assessment Not applicable (advisory use only, human review required)
Approved users Marketing, Sales (licensed users only)
Approval date 24 Aug 2026
Next review date 24 Feb 2027

Keep the register in a location your AI governance owner and DPO can both access and update. A shared document or a row in your existing risk register works. The format matters less than the discipline of keeping it current.

Map the data flow, not just the tool

A tool name and a risk rating tell you what the AI is, not what it touches. For each entry in the register, particularly anything medium risk or above, trace the path the data actually takes. This is also the version of the register that is useful in board or management reporting, where "what does this tool actually do with our data" is the first question asked.

Stage What to record
User Who provides the input, and whether they are a defined role or anyone with a licence
AI application The tool or interface the user interacts with directly
Model The underlying model or vendor providing it, including where it is hosted
Data What data the model can see or is trained on: only the prompt, or connected systems too
External systems Any API, plugin, or third-party system the AI can read from or write to on its own
Output Where the output goes: back to the user, into another system, or directly to a customer
Human decision or action Who reviews the output before it has a consequence, and what they are able to change

A tool where every stage terminates with a human reviewing the output before anything happens is a materially different risk to one where the AI application can write directly to an external system with no stage in between. The classification framework in Step 2 formalises that difference; this map is what makes the difference visible in the first place.

Step 2: Classify tools by risk

Not every AI tool needs the same level of control. A grammar checker and a CV screening system are both AI, but the governance requirement for each is completely different. The classification framework below uses two axes: what data the tool processes, and what decisions it influences.

🟢
Low risk: public data, no individual decisions
AI tools that process only non-sensitive business information and do not influence decisions affecting individuals. Examples: using an AI writing tool to draft marketing copy from a brief, summarising publicly available research, generating code from a non-sensitive technical description (provided the output is reviewed for security vulnerabilities, licensing issues, and quality before use). Controls required: acceptable use policy confirmation, no personal or confidential data input.
🟡
Medium risk: business or personal data, advisory outputs
AI tools that process internal business data, customer information, or employee data and produce outputs that humans use in their work. Examples: Microsoft 365 Copilot summarising emails, AI drafting customer communications from CRM data, meeting transcription tools. Controls required: data processing agreement with the vendor, defined data categories permitted, mandatory human review before sending AI-generated content externally, staff training.
🔴
High risk: decisions affecting individuals
AI tools that make or materially influence decisions with significant effects on individuals: employment, credit, insurance, benefits, or legal matters. Controls required: Data Protection Impact Assessment (DPIA), documented human oversight with a named accountable person, mechanism for individuals to request human review, Article 22 compliance assessment, and board-level awareness.

Additional classification dimensions

Beyond the three tiers above, four additional dimensions refine the classification and identify where enhanced controls are needed:

  • Autonomy level: is the AI purely assistive (draft text for a human to review), advisory (recommends an action), semi-automated (requires human approval to proceed), or fully automated (acts without human intervention)? Treat any system capable of taking an action on its own, sending an email, updating a record, calling another system or API, as a default high-risk classification regardless of how sensitive the underlying data is: the risk in an agentic system comes from what it can do, not only from what it can see.
  • External exposure: does the AI process or produce output that goes to customers, partners, or the public, or does it stay entirely internal?
  • Regulatory exposure: does the use case fall under a sector-specific regime such as FCA, NHS DSP Toolkit, DORA, or the EU AI Act for organisations with EU operations?
  • Data sensitivity: public and non-personal data, internal business data, personal data, confidential or legally privileged material, or special category data such as health or biometric information?

A tool that scores medium on the primary risk tier but also involves full automation, customer-facing outputs, and special category data should be treated as high risk in practice. Use the dimensions to sense-check the primary classification rather than override it mechanically.

Step 3: Write an AI acceptable use policy

An AI acceptable use policy sets the rules staff follow when using AI tools at work. It does not need to be long. A policy that staff can read in five minutes and apply without asking for clarification is more valuable than a comprehensive document that no one reads.

What to include

1
Approved tools list
Name which AI tools are approved for business use. Include any conditions, such as "Microsoft 365 Copilot for internal use only" or "approved for drafting, not for sending without review". Tools not on the list require IT approval before use.
2
Data input restrictions
Define what must not be entered into any AI tool, approved or otherwise. Minimum: personal data about identifiable individuals, customer account data, financial records, legal documents, and unpublished intellectual property. Be specific enough that staff can make the call themselves.
3
Output review requirement
AI outputs must be reviewed before being acted on, sent to customers, or published. The reviewing person takes responsibility for the content. Define what review means: reading it, fact-checking it, or a more formal approval process depending on the use case.
4
No personal accounts for business use
Staff must not use personal free-tier AI accounts for business tasks. Personal accounts typically have broader data use rights in their terms of service, and the organisation has no control over or visibility into what is processed.
5
Disclosure requirements
Set expectations for when AI involvement must be disclosed: in customer-facing content where your sector has disclosure requirements, in documents submitted to regulators, and internally when an AI tool contributed materially to a decision.
6
How to request a new tool
Give staff a clear route to request approval for an AI tool they want to use. If the process is unclear, they use the tool anyway and do not tell anyone.

Assign a named owner for the policy and set a review date. Given how fast AI capabilities and vendor terms change, a six-month review cycle is more useful than an annual one.

Example policy rule

Employees may only use AI tools approved by the organisation. Confidential, personal, customer, financial, legal, or otherwise restricted information must not be entered into any AI system unless the tool and use case have been explicitly approved. AI-generated content must be reviewed by an appropriately authorised employee before being used in consequential decisions or external communications.

Common questions

What should an AI acceptable use policy include?

An AI acceptable use policy should cover: which tools are approved and under what conditions; which data categories must not be entered into any AI system (personal data, customer data, financial records, legal documents, intellectual property); the requirement to review and take responsibility for AI outputs before using them; prohibition on personal free-tier accounts for business purposes; disclosure expectations when AI is used in customer-facing or regulatory content; and how to request approval for a new tool. Keep it short enough that people read it and specific enough that they can apply it without asking for clarification on every case.

Sources

AI Governance Assessment

Not sure where your AI governance stands?

We assess your AI inventory, risk classification, privacy obligations, security controls, and governance structure. Deliverable: a gap assessment and prioritised 90-day roadmap.

  • ✓ What AI tools are in use and what data they process
  • ✓ Which use cases require additional controls or a DPIA
  • ✓ Where security controls for AI need to be strengthened
  • ✓ Whether EU AI Act or sector regulation applies
  • ✓ Who owns governance, approves tools, and handles incidents
  • ✓ Prioritised 90-day roadmap to close the gaps

Disclaimer: This article is for general informational purposes only and does not constitute legal, regulatory, or professional advice. Cyvra makes no warranty as to the accuracy or completeness of this content, which may not reflect the most current regulatory developments. Readers should seek independent legal and regulatory advice appropriate to their specific circumstances. Cyvra accepts no liability for any loss arising from reliance on this content.