Getting started safely
What to settle before the first document goes into a tool: data, legal basis, approval, and the two rules that avoid most of the trouble.
The two rules
A good first task
- Occurs frequently, at least weekly.
- Has a result that can be checked unambiguously.
- Contains no or only limited personal data.
- Has a named responsible person.
- Has a baseline from today, at least roughly estimated.
Tasks meeting those five: structuring meeting notes, routing incoming post, rendering text in plain language, drafting recurring letters.
What is not for the start
Anything with legal consequences, anything with deadlines, anything deciding about people, and anything that goes out unchecked.
The check before the first document
- 01
Which data is involved?
Not which was planned but which actually ends up in the input. A meeting note contains names even where nobody intended that.
- 02
Is there a legal basis?
Always, for personal data. Consent is the weakest route in employment, see legal bases.
- 03
Has the provider been checked?
Processing agreement, server location, sub-processors, exclusion of training use. All four, not three of them.
- 04
Who decides, and who checks?
One named person per task. Without a name there is no responsibility.
The one-page policy
- Which tools are approved, and for which kinds of data?
- What must expressly not be entered? A short, concrete list.
- Who checks an output before it leaves the building?
- Where do you ask when something is unclear? A name, not a shared mailbox.
- How do you report that something went wrong, without penalty?
The last point is the most often forgotten and the most important. If a mistake cannot be reported without consequence, it does not get reported.
What to settle legally
| Point | Basis | Typical mistake |
|---|---|---|
| Legal basis | Art. 6, Art. 9 for special categories | Consent in employment |
| Processing on behalf | Art. 28 GDPR | Contract without sub-processor terms |
| Third-country transfer | Chapter V GDPR | Server location checked, group access not |
| Purpose limitation | Art. 5(1)(b) | Existing data used for training |
| Co-determination | Works constitution law | The tool is capable of performance monitoring |
| Record of processing | Art. 30 GDPR | New processing not entered |
| Deployer duties | AI Act | Role not determined, risk class not assessed |
The penultimate row is the one most often missed: almost any tool recording handling times or usage frequency is capable of conduct or performance monitoring, regardless of intent.
Finding and folding in shadow AI
- Check network logs and expense claims for provider access. That finds more than any survey.
- Declare an amnesty period: whoever reports what they use gets it assessed rather than banned.
- Offer a fast approval route. A process taking six weeks creates shadow AI rather than removing it.
- Turn the result into an inventory, see approval process.
The input rule to put on the wall
FREE ACCOUNT
Input rule and start checklist
A single page for the team: what may go in, what may not, and what to do after a slip.
Templates2 items