AI Acceptable Use Policy Template (For Small and Mid-Sized Businesses)
Once employees start using AI on their own — pasting customer data into ChatGPT, generating contracts with Claude, summarizing meetings with whatever tool a vendor sold them — you have an AI policy whether you wrote one or not. The choice is between writing it deliberately or discovering it the hard way after a data leak. This template covers the eight sections every small or mid-market business should have in writing: who can use AI, what data is off-limits, approved tools, disclosure rules, decision-making boundaries, vendor management, incident response, and review cadence. Adapt the bracketed sections to your business, get a lawyer to glance at it, and roll it out in 30 minutes.
How to Use This Template
Each section below has a default policy line in plain English, followed by [BRACKETS] showing where to customize for your business. The defaults are written for a 10–500 person company without a dedicated compliance team. If you're in a regulated industry (healthcare, finance, legal), have your counsel review before adopting — the defaults are sensible starting points, not legal advice. Total length should land between 4–7 pages when adapted.
Section 1: Scope and Purpose
**Default policy:** This policy applies to all [COMPANY NAME] employees, contractors, and third parties when they use any AI tool — including but not limited to ChatGPT, Claude, Gemini, Copilot, Notion AI, Grammarly, and any AI features built into other software — in the course of [COMPANY] business. The purpose is to protect customer and company data, prevent unauthorized decisions being delegated to AI, and ensure compliance with applicable regulations.
**Why this section matters:** Without explicit scope, employees argue that 'just summarizing notes' or 'just helping me write an email' isn't covered. Cover everything; allow exceptions in writing.
Section 2: Who Can Use AI (Permission Tiers)
**Default policy:** AI usage is permitted at three tiers. All employees default to Tier 1 unless explicitly granted higher access by [POLICY OWNER ROLE].
• **Tier 1 — Personal productivity only:** Brainstorming, drafting first drafts of internal-only content, summarizing public information. No customer, financial, or HR data.
• **Tier 2 — Internal data permitted:** Tier 1 plus internal documents, meeting notes (without external attendees by name), and operational data. Requires team lead approval and a signed acknowledgment of this policy.
• **Tier 3 — Customer and sensitive data:** Tier 2 plus identifiable customer data, contract drafting with PII, financial analysis. Requires [EXECUTIVE ROLE] approval, an approved tool from the allowed list, and quarterly access review.
**Why this matters:** Tiered access prevents the most common failure mode — well-meaning employees pasting customer SSNs into a free AI tool that explicitly logs all inputs for training.
Section 3: Approved Tools List
**Default policy:** Only AI tools on the approved list below may be used for [COMPANY] business. Any other tool requires written approval from [POLICY OWNER ROLE] before use, including 'free' or trial versions.
**Approved tools (example — customize to your stack):**
• [TOOL NAME] — Tier [N] access — covered by Business Associate Agreement / DPA dated [DATE]
• [TOOL NAME] — Tier [N] access — enterprise SSO required
• [TOOL NAME] — Tier [N] access — usage logged via [LOGGING SOLUTION]
**Specifically prohibited:** Free consumer-tier accounts (ChatGPT Free, Claude Free, etc.) for any work-related task involving non-public data. The training data and retention policies on consumer tiers are not compatible with [COMPANY]'s data obligations.
**Why this matters:** Most data leaks happen via free consumer tools because employees don't realize that 'free' usually means 'data trains the model.' A short approved list is the single most effective policy control.
Section 4: Data Boundaries (What Never Goes Into AI)
**Default policy:** The following categories of data must never be entered into any AI tool — regardless of tier, regardless of approval — without explicit written authorization from [LEGAL/COMPLIANCE ROLE]:
• Customer Social Security numbers, driver's license numbers, passport numbers
• Financial account numbers (credit cards, bank accounts) — except via approved tools with redaction
• Protected health information (PHI) as defined under HIPAA
• Information subject to legal hold, NDA, or active litigation
• Trade secrets and source code containing proprietary algorithms
• Personnel files, performance reviews, salary information
• Strategic plans not yet announced internally
• Customer communications when customer hasn't consented to AI processing
**When in doubt, don't paste.** Ask [POLICY OWNER ROLE] before, not after.
**Why this matters:** The hardest cases are gray-area data — meeting notes that 'mention' a customer, a draft contract with 'just the framework.' Define clear bright lines so employees don't have to make judgment calls under deadline pressure.
Section 5: Disclosure Requirements
**Default policy:** When AI materially contributed to externally-facing output, [COMPANY] discloses appropriately:
• **Customer communications:** AI-drafted communications must be reviewed and edited by a human before sending. The final responsibility is with the sender, not the AI. No specific disclosure required for routine communications.
• **Contracts and legal documents:** AI may be used for drafting and review; final documents must be reviewed by qualified counsel or designated reviewer. The fact that AI was used in drafting is internal information.
• **Public content (marketing, blog posts, social):** Substantive AI-generated content should be reviewed for accuracy, originality, and brand voice. Disclosure is at [COMPANY]'s discretion based on platform requirements and best practice.
• **Decisions affecting customers (pricing, denials, recommendations):** Any automated or AI-assisted decision that affects a customer's outcome must be disclosed in the customer-facing decision communication, with a human review option offered.
• **Regulated industries:** Additional disclosure may be required by [INDUSTRY-SPECIFIC REGULATIONS]. See [LEGAL/COMPLIANCE].
**Why this matters:** Disclosure rules vary wildly by industry and jurisdiction. Default to honesty — but be explicit about what 'AI used' means so employees aren't over- or under-disclosing.
**Default policy:** AI is a tool for analysis and drafting, not a decision-maker. The following decisions must always involve a human with appropriate authority — AI may inform, but cannot decide:
• Hiring, firing, promotion, compensation, or any HR action
• Customer credit, lending, or insurance approvals/denials
• Contract execution or commitment of [COMPANY] funds above [$ AMOUNT]
• Pricing changes affecting more than [N] customers
• Public statements on behalf of [COMPANY]
• Legal positions, regulatory filings, or disclosures
• Actions that affect customer health, safety, or financial wellbeing
• Escalations involving complaints, threats, or regulatory matters
**For all other AI-assisted work**, the human reviewing the output is accountable for the final result. 'The AI did it' is not a defense.
**Why this matters:** Algorithmic decision-making is increasingly regulated (NYC Local Law 144, EU AI Act, etc.). Even where not yet regulated, automated denial without human review is a fast track to customer-trust damage.
Section 7: Vendor and Third-Party AI
**Default policy:** Before adopting any new AI tool or AI-enabled feature of an existing tool, [POLICY OWNER ROLE] must verify:
1. Data residency and access rights (where does our data go, who can read it)
2. Training opt-out (our data is not used to train shared models — in writing, not verbally)
3. Subprocessor list and security certifications (SOC 2 Type II or equivalent)
4. Incident notification commitment (we are notified within [N] hours of any breach affecting our data)
5. Data export and deletion rights at contract end
6. Liability and indemnification terms appropriate to data sensitivity
**Vendors changing AI features mid-contract:** If a vendor adds AI to an existing product mid-contract (e.g., 'our help desk now uses AI to suggest responses'), the new feature must be opted-out by default and reviewed under this policy before being enabled.
**Why this matters:** Vendor sprawl is the silent risk. The CRM you signed in 2023 may have added AI features in 2025 that your team enabled without realizing it changes the data flow.
Section 8: Incident Response and Policy Review
**Default policy:** If an employee or contractor becomes aware of an AI-related incident — sensitive data entered into a non-approved tool, AI output that was sent and was materially wrong, an AI tool behaving unexpectedly, or a vendor breach — they must report it to [POLICY OWNER ROLE] within 24 hours.
**Reporting is not punitive.** Honest reporting is rewarded; concealment is grounds for discipline. We expect mistakes; we cannot tolerate hidden mistakes.
**Policy review:** This policy is reviewed [QUARTERLY / SEMI-ANNUALLY] by [POLICY OWNER ROLE] with input from [LEGAL, IT, OPERATIONS]. AI technology and regulation are changing fast — a policy that hasn't been updated in 12 months is probably out of date.
**Acknowledgment:** All current employees and contractors must acknowledge this policy within 30 days of issuance, and all new hires within their first 14 days. Acknowledgment is recorded by [HR / POLICY MANAGEMENT TOOL].
**Effective date:** [DATE]. **Owner:** [POLICY OWNER ROLE]. **Next review:** [DATE].
Implementation Checklist (After Adapting the Template)
1. Replace every [BRACKET] with your specifics. Don't ship a policy with [PLACEHOLDER] text — employees will lose trust in it instantly.
2. Have legal counsel or compliance reviewer read it once before signing — 30 minutes of their time saves you from a 6-figure regret.
3. Build the approved tools list with your IT lead and the team that actually uses AI day-to-day. A theoretical list nobody uses is worse than no list.
4. Pick a policy owner with real authority — usually a department head or COO. AI policy that lives with 'whoever' fails within 90 days.
5. Train every employee in a 30-minute live session, not just an email blast. Take questions. The questions are the real risk surface.
6. Set the review date in [POLICY OWNER]'s calendar before the policy ships, not after.
7. Test the incident reporting path within 60 days — send a fake incident through the channel to verify it works.
Frequently Asked Questions
Frequently Asked Questions
Yes. A 5-person company has the same data obligations as a 500-person company — and one wrong paste of a customer file into a consumer AI tool produces the same notification requirement. The policy at 5 people is shorter and simpler, but the bright lines (what data never goes in, who approves new tools) are identical.
Vendor-side AI features. Most policies focus on standalone AI tools like ChatGPT, but the real exposure is the AI features your existing CRM, help desk, accounting, and HR tools quietly added over the last 18 months. Section 7 of this template exists specifically to close that gap.
For work involving customer data or proprietary information, yes. For personal productivity tasks with no company data (brainstorming, summarizing public articles, learning a new topic), it's reasonable to allow free tools under Tier 1. The line is the data, not the tool.
Quarterly for the first year, then semi-annually if things have stabilized. Frontier model providers (Anthropic, OpenAI, Google) ship meaningful capability upgrades every 3–6 months, and regulation is moving fast — a static AI policy is an unreliable one.