What the draft is built from
Two sources:- your onboarding questionnaire answers
- your current Tool Register
Generating
Open AI Policy. If you have no policy yet you will see No policy generated yet and a button to generate one. It takes a moment, then the document appears as Version 1. The first time you open it, a panel explains where the policy came from and when to regenerate it. You can dismiss it once you have read it.What to check before you adopt
Work through the document with the section rail on the left. Five things repay the attention:Anything naming a person
Anything naming a person
Roles, the AI Oversight Lead, whoever the policy says is accountable. Clause 3.2 requires roles and responsibilities to be clear, and a policy naming someone who left is worse than one naming nobody.
Any stated frequency
Any stated frequency
Training intervals, review cycles, monitoring cadences. Every frequency in the policy is a commitment your firm has to be able to evidence. If the policy says quarterly and you manage twice a year, change the policy or change the practice.
The tools it describes
The tools it describes
Cross-check against your Tool Register. Missing tools mean the register was incomplete when you generated.
Anything about client data
Anything about client data
Clause 3.1 is strict about uploading private and confidential data to AI systems. Make sure the policy reflects what your firm actually does, not what it intends to do.
The human oversight section
The human oversight section
This is where the policy tells your own staff how to behave. If it is vague, your staff will be vague, and the Oversight Log entries they write will show it.
Then adopt it
An unadopted policy is a draft. Adopt and sign covers what happens next.Nothing stops you regenerating before adopting. If you spot that your Tool Register was incomplete, fix the register and regenerate rather than adopting a policy you already know is wrong.

