Microsoft 365 Copilot summarises meetings, drafts emails, analyses spreadsheets and searches documents. To do so it accesses the content the user may see in Microsoft 365. That makes it useful and at the same time a test of how orderly your environment is.
The core risk: oversharing
Copilot creates no new permissions; it makes existing ones visible. If a folder with payroll data sits in a site accidentally shared with everyone, Copilot finds it in response to a harmless question. What was protected by being hard to find is no longer protected with an AI assistant. Every rollout therefore starts with Microsoft 365 governance and a cleanup of the permission concept.
Preparation
Analyse and clean up shares with everyone and anonymous links, assign owners to teams without owners, introduce data classification with sensitivity labels, define data loss prevention rules and write a usage policy stating what Copilot is used for and where outputs must be checked.
Data protection and AI regulation
Processing of personal data falls under the FADP and GDPR; Microsoft acts as processor, and contracts and data locations must be reviewed. As a general assistant Copilot is usually not a high-risk system under the AI Act, but the AI literacy duty and your own AI governance still apply. If outputs are used for decisions about people, for example in HR, a closer look is needed.
Staged rollout
A pilot group with clear use cases, measurement of benefit, training on good prompts and on checking outputs, then gradual expansion. Whether now is the right time is weighed in our Copilot decision guide.