Thinking about bringing Microsoft 365 Copilot into your organisation? You’re not alone. Plenty of businesses are exploring how this AI assistant can boost productivity, streamline processes, and make day-to-day work easier. But with all that power comes a crucial question: what does it mean for your personal and confidential data?
If you’re introducing any new technology that processes personal data, you need to consider the potential risks, and that means doing a Data Protection Impact Assessment (DPIA). It’s not just a box-ticking exercise; it’s a practical way to understand what Copilot is doing with your data and how to keep it safe.
Why Bother with a DPIA?
Under UK GDPR, you’re legally required to conduct a DPIA if there’s a high risk to individuals’ rights and freedoms. The Information Commissioner’s Office (ICO) also flags innovative tech and new organisational solutions as triggers for a DPIA and Microsoft 365 Copilot fits the bill.
Even if a DPIA isn’t mandatory, it’s still a smart move. It forces you to think about how personal data flows through your organisation and helps you spot any risks before they become real problems. A DPIA is a great way to fully assess the potential impact of new solutions on any personal data you hold or process.
What Should You Be Thinking About?
Copilot can do a lot, drafting documents, analysing spreadsheets, summarising meetings, and more. But wherever personal data is involved, you need to take a closer look. Here are some key questions to guide your DPIA:
- What personal data is affected?
- Have you mapped out your Copilot use cases and identified where personal data is involved?
- Are your purposes clear and lawful?
- Are you using Copilot to enhance existing processes, or is it creating new ones? What legal basis are you relying on? And is the data processing genuinely necessary?
- Are you minimising data use?
- How will you ensure that Copilot only accesses the data it needs? Think about using indexing, access controls, and labelling to limit what Copilot can see.
- Are you being transparent?
- Are staff and other stakeholders aware you’re using Copilot to process their data? Are you giving them the option to opt out of AI-driven tasks, like having meetings transcribed and summarised?
- How accurate is the output?
- AI isn’t perfect. Misinterpretations and inaccuracies happen, especially if the data Copilot pulls from is out of date or biased. How will you check and validate its outputs?
- Are staff trained and aware?
- Do your people know how to use Copilot responsibly? Are they aware of the risks, like including confidential information in prompts, and are those risks reflected in your policies?
- What about new data generated by Copilot?
- Copilot logs prompts, responses, and audit trails. Have you updated your Record of Processing Activities (ROPA) and retention schedules to account for this?
- Have you considered technical security?
- Are you using file labelling and access controls to manage sensitive data? Have you disabled web searches to keep prompts within your Microsoft environment? What other security settings have you reviewed?
- Are there international data transfers?
- If Copilot processes data in non-EU locations, have you reviewed the relevant international transfer safeguards?
Get It Right from the Start
Rolling out Microsoft 365 Copilot without considering data protection is a gamble. A robust DPIA will help you manage risks, protect people’s data, and stay on the right side of the law.
Need help? We’ve got you. We’re here to help you tackle your Copilot DPIA and ensure your AI journey is smooth, secure, and compliant.
Our team is ready to guide you through what you need to do. Get in touch at info@evolvenorth.com or call us on 01748 905 002