Copilot and AI in business: what needs settling before the rollout?

If you are rolling out Copilot, there are five things to settle first: permissions, data processing, licences, rules for staff and the scope of the start. Switching Copilot on takes little time. What it then finds depends on how your Microsoft 365 environment looks today. I put the five points in context from a technical perspective. This does not replace legal advice.

Permissions: Copilot makes visible what is already shared

Microsoft is clear on this: Copilot shows only company data for which a person has at least read access. So no new permissions arise. What is new is how easily existing permissions can be used. Until now, someone had to know where a file was. Now a question is enough.

Oversharing of this kind arises easily when sharing settings are too generous. Before the start, I therefore look mainly at the following:

• Broad sharing: “Anyone” links, links for everyone in the organisation and the group “Everyone except external users”.
• Sites without owners: public teams, ownerless and long-unused SharePoint sites.
• Sensitive content: HR, finance and contracts, especially where they coincide with broad sharing.
• Mailboxes: Copilot can also use shared and delegated mailboxes that a person is allowed to access.
• External people: permissions for people outside the company, for example in shared Teams channels, also belong in the review.

For reviews of this kind, Microsoft offers SharePoint Advanced Management. It does not come automatically with every Microsoft 365 licence. I clarify that before the start.

If the start is urgent, individual sites can be kept out of Copilot and organisation-wide search with Restricted Content Discovery. The permissions themselves stay unchanged. That bridges the time until the tidy-up, but does not replace it.

Data protection: where your data is processed

With a work account, prompts and responses are covered by the same contractual commitments as emails and files in Microsoft 365, including the Data Protection Addendum, Microsoft’s data processing agreement. According to Microsoft, it does not use this data to train the foundation models. Prompts and responses are stored. Administrators can view them through Microsoft Purview and set retention periods.

For customers in the EU, Microsoft’s EU Data Boundary commitments apply to Copilot in principle. That is the boundary within which Microsoft stores and processes data. This does not mean that all processing takes place in the EU. There are exceptions:

Three areas whose settings you should check

Availability and defaults differ by service and tenant.

What applies when the setting is active?

Web search

Search queries go to Bingoutside the Data Protection Addendum and the EU Data Boundary

Flex routing

At peak load, also outside the EUmodel processing possible in the USA, Canada or Australia

Anthropic models

Processing outside the EU Data BoundaryAnthropic is a Microsoft subprocessor

I do not decide these three settings across the board, but with each customer, case by case.

I am not a lawyer. Whether a data protection impact assessment is needed, what belongs in the record of processing activities and whether a works council has a say are matters to settle with your data protection officer or a lawyer. I supply the technical details for this: which data flows where and which settings are in place. Microsoft also provides a template for assessing the risks of Copilot.

Licences: what is included and what you buy

Offer	What it accesses	Licence
Copilot Chat	Web, content you provide yourself, in supported versions of Outlook also limited access to emails, appointments and chats	Included in eligible Microsoft 365 plans
Microsoft Copilot, formerly Microsoft 365 Copilot	In addition, emails, files, meetings and chats across Microsoft 365, as far as the person is allowed to see them	Add-on licence per person
Copilot Business	The same features as Microsoft Copilot	For businesses with up to 300 users, annual commitment

Copilot Business requires a suitable base licence, such as Business Basic, Business Standard or Business Premium. What that costs and when the bundle with Business Premium pays off is covered in the article Copilot Business with Business Premium.

Do not buy for everyone straight away. For one customer, I assigned the licences through a group and later moved a licence from one person to another. On an annual commitment the number of licences is fixed; who uses them can change.

Rules for staff: better before you buy licences

Many teams have been using AI for some time, often without shared rules. Copilot Chat is available to eligible users without an add-on licence, and private accounts with other providers may be running alongside it. Two risks stand out for me: confidential data in private AI accounts and incorrect answers adopted unchecked. Your rules should cover these points:

• Permitted tools: only approved services and only with the work account. Microsoft’s data protection commitments for Copilot apply when signing in with the company account, not with private accounts.
• Data: which content may go into which service, and which never may? HR data, customer data and trade secrets should be named explicitly.
• Duty to check: answers are drafts. Microsoft does not guarantee that they are correct either. Responsibility stays with whoever uses them.
• Decisions about people: applications and performance reviews need a clarification of their own, not just a rule of thumb.
• Meetings: in Teams, Copilot can also work with a saved transcript. Decide when meetings are transcribed and how participants are told.

Bans alone rarely help. For one customer, I distributed the ChatGPT app for Windows and iOS through device management. In this way an approved tool can be provided centrally, rather than everyone installing something themselves. I draw up the rules themselves together with you.

I would advise against three things: customer data in free accounts, using results without checking them and introducing AI without a specific use case.

What the EU AI Act requires here

Two points also affect small businesses. First, AI literacy: under Article 4, businesses that use AI professionally must take measures to support the AI literacy of their staff. The obligation has applied since 2 February 2025, and since July 2026 in amended form. Nobody has to guarantee a particular level. A certificate is not required; internal records are possible. Even those who use ChatGPT only for advertising copy should, according to the Commission, be informed about risks such as made-up answers. I offer the course “Using AI tools safely” and courses on ChatGPT, Claude and Copilot in Campus, with a certificate per person.

Second, HR: AI that sorts job applications, for example, counts as high-risk. As things stand, the obligations for this apply from 2 December 2027. Whether and how that applies to your use is a legal question.

Rolling out Copilot: pilot first, then decide

How I go about it

1. Review permissionsbefore it is first switched on
2. Define use casesspecific tasks rather than AI in general
3. Small pilot groupusually 3 to 5 people, depending on the company
4. Trainingwith examples from your own working day
5. Assess the benefitafter a few weeks
6. More licencesonly then

A pilot answers the question no data sheet can: does Copilot save time in your working day? In my view it is most likely to pay off for drafting texts and emails, summarising meetings and searching documents. Microsoft’s usage reports show how much Copilot is actually used. Whether it helps, you will only learn from the people involved.

There is one thing a pilot does not do: it does not limit what the participants see. Even the first test user finds everything shared with them. That is why the permissions review comes before the start, not after it.

Frequently asked questions

I hear the first two questions most often.

“Where do we start?”

With the permissions and a specific use case. Then come a small pilot group and training with your own examples. More licences follow only once the benefit has become clear.

“Is our data safe?”

That depends above all on three things: the accounts, the permissions and the settings. Copilot works with each person’s existing permissions and shows nothing they are not allowed to see. Permissions can, however, be wider than the company realises. Confidential data also has no place in private AI accounts.

Is Copilot Chat enough to begin with?

For getting used to AI, for writing and for research, often yes. Access to company data across Microsoft 365 comes only with the licence. For Copilot Chat too, the rules and the web search setting should be settled.

Is Copilot available without Microsoft 365?

For business use as described here, Copilot requires a suitable Microsoft plan. Depending on which data should not leave the company, your own AI assistant or a local model may also be a fit. I describe these routes under Automation & AI.

Sources

• Permissions, data protection, EU Data Boundary, storage: Microsoft Learn – Data, Privacy, and Security for Microsoft Copilot, Microsoft Learn – Microsoft Copilot overview
• Reviewing and limiting oversharing: Microsoft Learn – Get ready for Microsoft 365 Copilot with SharePoint Advanced Management, Microsoft Learn – Prerequisites for SharePoint Advanced Management
• Mailboxes: Microsoft Learn – Microsoft Copilot requirements
• Web search: Microsoft Learn – Data, privacy, and security for web search in Microsoft Copilot
• Flex routing: Microsoft Learn – Flex routing (EU and EFTA)
• Anthropic models: Microsoft Learn – Anthropic models in Microsoft Online Services, Microsoft Learn – Copilot in Microsoft 365 apps with Anthropic models
• Licences: Microsoft Learn – License options for Microsoft Copilot, Microsoft Learn – Overview of Microsoft Copilot Chat, Microsoft Learn – Plan licensing and cost
• Meetings: Microsoft Learn – Manage Microsoft Copilot in Teams meetings and events
• EU AI Act: Regulation (EU) 2026/1744, European Commission – AI Literacy: Questions & Answers, European Commission – AI Act
• All information as of 31 October 2026.