Copilot Policies: Best Practices
A practical policy blueprint for government organizations adopting Microsoft 365 Copilot. We'll cover the key policy areas you should define (acceptable use, verification, sensitive data handling, external sharing, and accountability), and how to make those policies usable—not just compliant.
Overview
If your organization’s Copilot policy is just “don’t do bad things,” you’ve got a problem. Users will either ignore it entirely or stop using Copilot out of fear. Neither outcome helps your mission.
Good policy doesn’t just prohibit risk. It defines safe defaults. It gives people clear decision rules. It aligns to technical controls so users experience consistent guardrails.
This video gives you a practical policy blueprint for government organizations adopting Microsoft 365 Copilot. You’ll learn the five core policy areas you need to define—acceptable use, verification, data handling, external sharing, and accountability—and how to make those policies enforceable, not just aspirational.
What You’ll Learn
- Acceptable Use Policy: How to define allowed and prohibited use cases with clear examples
- Verification Requirements: When and how users must review Copilot output before use
- Data Handling Rules: How to tie Copilot use to your existing classification and labeling framework
- External Sharing Boundaries: Clear rules for guest collaboration and external communication
- Accountability Framework: How to maintain “human in the loop” accountability and incident reporting
Script
Hook: policy should enable safe use, not just prohibit
If your Copilot policy is just “don’t do bad things,” users will either ignore it or stop using Copilot entirely.
And here’s the problem: neither of those outcomes is acceptable. Ignoring policy creates risk. Avoiding Copilot creates missed opportunity. Both hurt your mission.
A good policy gives people safe defaults and clear decision rules. It tells them what they can do, not just what they can’t. It makes compliance the path of least resistance.
That’s what we’re building today. A Copilot policy that’s clear, enforceable, and aligned to technical controls.
Let’s start.
Policy area number one: acceptable and prohibited use
Your first policy area is acceptable use. This is where you define what Copilot is for and what it’s not for.
Start with allowed categories. Be specific. Give examples people can pattern-match against.
For instance: summarizing internal materials for briefings. That’s a clear, safe use case. Drafting routine communications for review—emails, meeting agendas, status reports. Another good one. Brainstorming outlines and ideation for research or planning tasks. That’s appropriate too.
The key word there is “for review.” You’re not approving final outputs. You’re approving draft assistance.
Now define prohibited categories just as clearly.
Unreviewed mission-critical decisions. If the output goes directly into a decision without human review, that’s prohibited. Sharing sensitive data outside approved boundaries—like copying classified or CUI content into unapproved systems. That’s a hard no. Using Copilot to draft communications that represent official agency positions without proper review and approval. Also prohibited.
Here’s the government-specific callout you need to include: Be explicit about mission domains where verification is mandatory.
If you’re in acquisition, spell out that contract language must be reviewed by legal. If you’re in healthcare, specify that clinical recommendations require licensed review. If you’re working with controlled unclassified information, state clearly that CUI handling rules still apply.
Don’t assume users will figure it out. Tell them.
And here’s a pro tip: organize your policy by use case, not by technology feature. Users don’t think in terms of “Chat versus Pages versus integration APIs.” They think in terms of “Can I use this for acquisition memos?” or “Can I use this to summarize audit findings?” Write your policy that way.
Policy area number two: verification and citations
Your second policy area is verification. This is non-negotiable. Copilot output must be reviewed before use. Full stop.
But here’s where you need to add nuance. Not all review is the same. Some outputs need light verification. Some need subject matter expert review. And some need formal approval chains.
So define your verification tiers clearly.
Tier one: self-review. The user who generated the output is responsible for checking it. This applies to routine, low-stakes drafting—things like meeting summaries, brainstorming notes, and informational emails. The user owns accuracy.
Tier two: second reviewer required. For anything mission-critical, regulated, or externally shared, require a second set of eyes. This could be a supervisor, a subject matter expert, or a designated reviewer depending on your agency’s approval structure. Examples: acquisition documents, policy guidance, external communications, anything that represents an official agency position.
Tier three: formal approval required. For high-consequence outputs like legal opinions, clinical decisions, or financial determinations, Copilot assistance doesn’t change your approval process. If it required three signatures before, it requires three signatures now.
Here’s another key point: encourage checking citations when they’re available. Copilot in Microsoft 365 provides citations to source documents. Train users to click through and verify that the source actually supports the claim. Don’t just assume Copilot got it right.
And be explicit in your policy: the person who uses Copilot output is accountable for its accuracy. The tool doesn’t own the decision. You do.
Policy area number three: data handling rules
Your third policy area is data handling. This is where you tie Copilot use to your existing classification and labeling framework.
If you’ve already got policies for CUI, PII, PHI, financial data, or classified information, those policies still apply. Copilot doesn’t create exceptions. It creates a new workflow you need to address.
So make your data handling rules explicit.
First rule: Copilot respects the same data boundaries as any other Microsoft 365 tool. It can only access what the user can access. It respects sensitivity labels. It honors DLP policies. Make sure users understand this—it’s not a separate system with separate rules.
Second rule: be clear about copying outputs into systems of record. If a user generates a draft in Copilot and then copies it into an official case management system, a records repository, or an external communication channel, standard handling rules apply. Label it correctly. Route it through the right approval process. Retain it according to your records schedule.
Third rule: define what happens when Copilot is used with regulated datasets. If your agency handles PII under the Privacy Act, specify that Copilot interactions with PII must be logged and that outputs containing PII must be labeled. If you handle PHI under HIPAA, state explicitly that Copilot use doesn’t change your minimum necessary standard or your disclosure accounting requirements. If you handle financial data under FISMA, clarify that audit trails still apply.
Here’s the alignment point you need in your policy: Copilot data handling rules must align with your DLP policies and your sensitivity labels. If DLP blocks sharing Social Security numbers externally, Copilot shouldn’t create a workaround. If a document is labeled “Controlled Unclassified,” that label should govern how Copilot output is handled.
And one more thing for government environments: be explicit about environment boundaries. If you’re in GCC, state that Copilot operates within your GCC tenant and doesn’t cross into commercial environments. If you’re in GCC High or DoD, clarify that your data stays in your authorized boundary.
Users need to know this. Put it in writing.
Policy area number four: external sharing and collaboration
Your fourth policy area is external sharing and guest collaboration. This is where agencies often have the most inconsistent practices, so it’s critical to define boundaries clearly.
First, define what “external” means in your context. Does it mean outside your agency? Outside the federal government? Outside the United States? Be specific. Different agencies have different boundaries.
Second, set a clear rule for external sharing of Copilot-assisted content. Here’s a good default: Copilot-assisted content must be reviewed before sending it externally. Period.
That means if a user drafts an email to a contractor using Copilot, they review it before hitting send. If they create a summary for a partner agency, they review it. If they generate a public-facing document, they review it and route it through your normal public affairs approval process.
The goal isn’t to slow everything down. The goal is to prevent unintentional disclosure of internal context, draft language that wasn’t meant to go out, or information that’s accurate internally but inappropriate for external audiences.
Third, address guest collaboration explicitly. If your tenant allows guest access—common in cross-agency collaboration or contractor partnerships—clarify how Copilot use works in shared channels and shared documents.
For example: if a guest user is in a Teams channel and a federal employee uses Copilot to summarize the conversation, does that summary get shared with the guest? Your policy should say. If a contractor has access to a SharePoint site and uses Copilot to draft a document there, does that require additional review before it becomes part of the official record? Your policy should address it.
Here’s the technical alignment point: your Copilot external sharing policy should match your Microsoft 365 external sharing settings. If you block external sharing at the tenant level, say so in your policy. If you allow it with conditions, spell out those conditions.
And for government environments, add this callout: in GCC High and DoD environments, guest access is more restricted by design. Your policy should reflect those technical boundaries and clarify what collaboration patterns are supported in your environment.
Policy area number five: accountability and reporting
Your fifth policy area is accountability. This is where you establish the “human in the loop” principle and define how users report problems.
Start with a clear accountability statement. Here’s the language you can adapt: “Users are accountable for the content they create, review, and distribute, whether assisted by Copilot or not. Copilot is a tool. The user owns the decision and the output.”
That statement matters because it prevents the “the AI told me to” defense. It also reinforces that using Copilot doesn’t reduce professional responsibility. It augments capability, but it doesn’t replace judgment.
Next, define what users should report and how. You need three reporting categories.
Category one: harmful outputs. If Copilot generates content that’s biased, offensive, factually wrong, or inappropriate, users need to know how to report it. This isn’t about blame. It’s about continuous improvement. Microsoft provides feedback mechanisms in Copilot, and you should have an internal channel too—maybe your IT service desk, maybe a dedicated AI governance inbox. Define it.
Category two: suspected data exposure. If a user believes Copilot surfaced data they shouldn’t have access to, or if they’re concerned about oversharing, they need a way to escalate that. This could be a security incident report, a privacy officer notification, or a help desk ticket depending on your agency’s structure. Make it clear.
Category three: policy confusion. If users don’t know whether a particular use case is allowed, they should have someone to ask. That might be a designated Copilot lead, a compliance team, or an internal collaboration channel. Don’t make people guess.
And here’s the cultural piece: frame reporting as a positive thing, not a punishment. You want people to surface issues early so you can address them. You don’t want them to hide mistakes or avoid using Copilot out of fear.
Close: make it adoptable
So you’ve defined acceptable use, verification requirements, data handling rules, external sharing boundaries, and accountability. That’s your policy framework.
But here’s the key to making it work: publish it in plain language, link it to training, and align it to technical controls so users experience consistent guardrails.
Don’t hide your policy in a five-hundred-page handbook. Put it on a SharePoint page. Create a one-pager. Record a short training video. Make it accessible.
Link it to onboarding and ongoing training. When users get a Copilot license, they should see the policy. When you roll out a new feature, remind them of the boundaries.
And align it to your technical controls—your DLP policies, your sensitivity labels, your audit logging, your access reviews. Policy without enforcement is just a suggestion. Enforcement without policy is just friction. You need both, working together.
Do that, and you’ll have a Copilot policy that’s not just compliant—it’s adoptable. And that’s the goal.
Sources & References
- Microsoft Copilot Adoption — Adoption guidance and recommended organizational readiness practices for deploying Copilot
- Copilot Privacy and Data Handling — Official documentation on how Copilot handles data, respects permissions, and maintains privacy boundaries
- Copilot Security Model — Overview of Copilot’s security architecture and how it inherits Microsoft 365 security controls