Generative AI Workplace Policy Template for UK Employers

This policy sets out [Organisation Name]’s requirements for the use of generative artificial intelligence (AI) tools by employees in the course of their work. It applies to all employees, contractors, and third parties working on behalf of [Organisation Name].

Generative AI tools include, but are not limited to, large language models, AI writing assistants, AI image generators, AI coding assistants, and AI productivity tools that generate text, images, code, or other content in response to user input. This policy applies to the use of all such tools, regardless of whether they are organisation-provided or personal tools used for work purposes.

The purpose of this policy is to enable productive use of AI tools while managing the risks to data protection, intellectual property, accuracy, and confidentiality that AI tool use creates.

Approved for general work use (subject to all conditions in this policy):

[List approved enterprise tools, e.g.: Microsoft Copilot (Microsoft 365 enterprise licence); Google Gemini (Google Workspace enterprise licence); [other approved enterprise tools with DPA in place]]

Approved for non-confidential, non-personal use only (brainstorming, general research, personal productivity — not for work documents containing personal or confidential data):

[List, e.g.: ChatGPT (free or Plus, without enterprise agreement); Claude.ai (without enterprise agreement)]

Prohibited for any work use:

Any AI tool not on the approved list above. Employees who wish to use a new AI tool for work purposes must request approval through [IT/Data Protection contact] before use.

Employees must not input any of the following into AI tools that do not have an enterprise data processing agreement (DPA) with [Organisation Name]:

— Personal data about customers, clients, employees, or any other individuals (including names, contact details, account information, health information, or any other information that identifies or could identify a person)
— Confidential client or customer information
— Commercially sensitive information (including unpublished financial data, pricing, strategy documents, or negotiating positions)
— Any information subject to a confidentiality obligation or non-disclosure agreement

Even for AI tools with enterprise DPAs, employees must check the relevant data processing agreement and confirm that the intended input is within the scope of that agreement before inputting personal or confidential data.

Processing personal data using AI tools without an appropriate DPA may constitute a breach of UK GDPR and must be reported immediately to [Data Protection contact] as a potential data incident.

All AI-generated outputs must be reviewed and verified by a qualified employee before use, sharing, submission to clients, or inclusion in any business document or communication.

The employee who uses an AI tool is responsible for the accuracy, completeness, and quality of the output — not the AI tool or its provider. AI tools can and do produce plausible but incorrect information (a phenomenon known as “hallucination”). Reliance on AI-generated content without verification is not an acceptable standard of care.

For professional, client-facing, or regulatory communications, employees must be able to verify each material claim in an AI-generated document from a reliable source before submission.

The intellectual property status of AI-generated works under UK law is uncertain. [Organisation Name] treats AI-generated outputs created in the course of employment as organisational work product, subject to the same ownership principles as other work product created by employees.

Where AI is used significantly in the production of a client deliverable, employees should consider whether the client contract includes IP warranties (such as warranties that “all work is original”) that may be affected by AI use. Where uncertainty exists, the matter should be referred to [Legal/Compliance contact] before submission.

Employees must not use AI tools to reproduce, transform, or build upon third-party copyrighted materials in ways that would exceed fair dealing or require a licence that is not in place.

Employees must disclose the use of AI tools to clients or regulators where:

— The client contract requires disclosure of AI use in deliverables
— Applicable professional or regulatory standards require disclosure (see sector-specific addendum)
— The AI has been used to generate substantive content in a professional opinion, advice document, or regulated communication
— The nature of the AI-generated content is material to the client’s ability to evaluate the deliverable

Where in doubt about whether disclosure is required, employees should discuss with their manager or [Legal/Compliance contact] before submitting the work.

Employees must complete [Organisation Name]’s mandatory AI literacy training before using approved AI tools for work purposes. The training covers: what generative AI tools do and their limitations; data protection obligations when using AI tools; output verification responsibilities; disclosure and IP requirements; and incident reporting.

Completion of AI literacy training will be recorded in [Learning Management System/HR System]. Access to approved enterprise AI tools may be restricted until training completion is confirmed.

Employees in roles with elevated AI risk (client-facing roles, regulated roles, roles with access to sensitive data) are required to complete additional role-specific AI training as specified by their manager or [HR/L&D contact].

Incident reporting: Employees must report the following to [Data Protection/IT Security contact] as soon as they become aware of them: suspected personal data input into an AI tool without a valid DPA; AI output errors that have been submitted to clients, regulators, or decision-makers without adequate verification; suspected misuse of AI tools by other employees in breach of this policy.

Data protection incidents involving AI tools must be assessed for notification obligations under UK GDPR Articles 33 and 34. The organisation has 72 hours from becoming aware of a reportable breach to notify the ICO.

Policy review: This policy will be reviewed at least annually, or earlier if significant changes occur in AI capabilities, applicable regulation, or the organisation’s AI tool usage. The policy owner is [Name/Role]. The next scheduled review date is [Date].