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AI Acceptable Use Policy vs AI Security Policy: Which Clauses Go Where and Who Enforces Them

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By NHI Mgmt Group, edited by Lalit Choda Updated 14 November 2026 17 min read
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Most organisations now have an AI policy, but many have one document trying to tell staff what they may paste into a chatbot, tell engineers how to secure a model endpoint and tell the board how AI risk is tiered, and it does none of the three well. An AI acceptable use policy (AUP) and an AI security policy answer different questions for different readers, are enforced by different mechanisms and change at different speeds. This guide is a clause allocation guide: it shows which requirements belong in the user-facing AUP, which belong in the AI security policy and its standards, which belong in neither, and who owns and enforces each one. It is for CISOs, AI governance leads, GRC teams and policy owners who are writing or splitting an AI document set. Ready-to-adapt wording is in the AI Acceptable Use Policy Template and the Agentic AI Security Policy Template; this page explains the boundary between them.

Key takeaways

  • Short answer: the AUP governs people, the security policy governs systems. The AUP tells every member of staff what they may and must not do with AI tools; the AI security policy tells the teams who buy, build and run AI what controls those systems must have.
  • Enforceability decides placement. A clause that you enforce through HR and acknowledgement belongs in the AUP; a clause that you enforce through architecture review, configuration baselines and audit belongs in the security policy and its standards.
  • Lists and values live outside both. Approved tools, model versions, data class limits and token lifetimes change monthly, so keep them in a register or standard that the policies reference, not in the approved policy text.
  • Agents sit on both sides. The AUP covers what a user may delegate to an agent acting with their access; the security policy covers how the organisation's own agents are identified, scoped, logged and stopped.
  • Frameworks expect both documents. NIST AI 600-1 calls for acceptable use policies for generative AI, ISO/IEC 42001 requires an AI policy and controls on responsible use, and EU AI Act Article 26 places operational duties on deployers that only a security standard can evidence.

Two documents, two audiences

The split mirrors the classic distinction between a rules of behaviour document and a security policy. NIST SP 800-53 Rev. 5 control PL-4 (Rules of Behavior) requires organisations to give people who need access "the rules that describe their responsibilities and expected behavior", to receive a documented acknowledgement before authorising access, and to have people re-acknowledge when the rules change. That is the AUP's job. CSF 2.0 GV.PO-01 asks for a policy for managing cybersecurity risk that is "established", "communicated and enforced", which is the security policy's job.

  • AI acceptable use policy: written for every employee, contractor and third party who uses AI for work. Plain language, readable in ten minutes, acknowledged on joining and on change, enforced through the disciplinary process. It covers approved tools, data rules, prohibited uses, human review of outputs, disclosure, delegation to agents and reporting.
  • AI security policy: written for system owners, AI platform teams, developers, procurement and the security function. It sets control objectives for AI systems the organisation acquires, builds or runs: identity and access for models and agents, data protection in pipelines, logging, testing, supplier assurance, incident handling and decommissioning. It is enforced through design review, release gates, configuration baselines and internal audit, and implemented through standards and procedures (see the Policy vs Standard vs Procedure vs Guideline guide for how those layers divide).
  • AI governance policy (the third document): the board-level statement of principles, risk appetite, roles and the AI risk tiering method. Both the AUP and the security policy sit under it. Wording is in the AI Governance Policy Template.

Side-by-side comparison

AttributeAI acceptable use policyAI security policy (with standards)
Primary readerAll staff, contractors, temporary workersSystem owners, AI and platform engineers, procurement, security operations
Question answeredWhat may I do with AI at work, and what must I never do?What must an AI system have before it goes live, and how do we keep it safe?
Subject of the rulesHuman behaviourSystems, configurations, suppliers and processes
Typical ownerAI governance group or CISO, with HR and legal sign-offCISO or head of security architecture
EnforcementAcknowledgement, training, monitoring of use, disciplinary processArchitecture review, release gates, baselines, audit findings, exception register
Change cadenceAnnual review, faster when a new class of tool appearsPolicy annual; standards whenever technology or threat changes
Worker consultationOften required (employment law, works councils)Rarely, unless it introduces staff monitoring
Framework anchorSP 800-53 PL-4 and PS-6; NIST AI 600-1 GV-1.4-002; ISO/IEC 42001 B.9CSF 2.0 GV.PO-01; ISO/IEC 42001 clause 5.2 and Annex controls; EU AI Act Article 26

What each document defends against

AUP threat model: the well-meaning or careless user

  • Data leakage through prompts and uploads: a user pastes customer records, source code or a contract into an unapproved tool whose terms allow training or retention.
  • Unvetted tools and delegated grants: a user signs up for a consumer AI app with a corporate account and grants it mailbox, drive or calendar scopes. The Vercel Context.ai OAuth breach began this way: an employee granted a consumer AI office suite broad access with a corporate Google account, the vendor was later breached and the stolen token gave the attacker the account.
  • Unsafe delegation: a user lets an agent send email, approve payments or change records with the user's own permissions.

Security policy threat model: the AI system as an attack surface

  • Prompt injection and tool misuse against applications and agents the organisation builds, including indirect injection through retrieved content.
  • Over-privileged machine identities: agents and model integrations holding long-lived API keys or broad OAuth scopes with no owner. See the Agent Identity and Access Guide.
  • Supply chain: third-party models, model hosting and plugins changing without notice; NIST AI 600-1 names "Value Chain and Component Integration" as one of its 12 generative AI risks.

A useful test: if the control fails because a person chose to break it, it belongs in the AUP. If it fails because a system was built or configured badly, it belongs in the security policy or a standard.

Clause allocation: which requirement goes where

The table allocates the clauses that most often end up in the wrong place. "Register" means the AI register or approved tools list, a controlled record outside both policies; see the AI Register and AI Inventory Template.

TopicIn the AUPIn the AI security policy or standardIn a register or other document
Data classesWhich classification may go into which tool status, in a simple matrix users can follow (for example Public and Internal into approved tools, Restricted nowhere without approval)Technical enforcement: DLP or gateway inspection of prompts and uploads, tenant restrictions, retention and training opt-out settings per serviceClassification definitions in the Data Classification Policy Template; per-tool data ceiling in the register
Approved toolsUse only tools in the register, under a corporate account; how to request a new oneAssessment criteria a tool must pass: SSO, logging, data residency, contractual no-training terms, admin consent for OAuth scopesThe tool list itself, with status (approved, approved with conditions, not approved)
Prohibited usesBehaviour-level bans: no restricted data in unapproved tools, no AI decisions about people without review, no impersonation, no bypassing controlsProhibited system designs: no autonomous action above a set risk tier without a human approval step, no shared credentials for agentsLegal list of prohibited practices under applicable law, maintained by legal
Human review of outputsUser duty to check accuracy, licensing and suitability before use or publicationRequired oversight points and override mechanisms designed into systems by risk tierRole assignments for oversight in the register entry
Agents acting for a userWhat a user may delegate, which actions need their confirmation, never sharing their credentials with an agentAgent identity, scoped and short-lived credentials, tool allowlists, action logging, kill switchAgent entry in the register with owner and sponsor
Organisation-built models and agentsNot covered beyond "follow the AI security policy if you build AI"Full lifecycle: threat modelling, red teaming before release, change control for model and prompt updates, decommissioningModel and system cards, test evidence
Risk tieringOne line: some uses need approval first, with a link to the request routeControl baselines per tier (what a high-tier system must have)The tiering method and criteria in the AI governance policy
Logging and monitoringTransparency notice that AI use is monitored, what is logged and whyWhat systems must log, retention periods, who can access logs, alert use casesPrivacy notice and data protection impact assessment
IncidentsReport suspected misuse, leakage or harmful output, and howAI incident classification, response playbooks, regulator notification triggersIncident response plan
EnforcementConsequences of breach, aligned with the general Acceptable Use Policy TemplateExceptions process, risk acceptance authority, auditException register

Two clauses need care. Shadow AI handling straddles both: the user rule ("use only approved tools") sits in the AUP, while discovery, triage and blocking sit in the security side; many organisations give it a dedicated document, as in the Shadow AI Policy Template. Monitoring of staff use is a security control, but the notice to staff belongs in the AUP because transparency to the individual is what makes the monitoring fair and defensible under employment and data protection law.

Ownership and enforcement

ElementAccountable ownerConsulted before approvalEnforcement mechanismEvidence
AI governance policyBoard or executive risk committeeCISO, legal, privacy, data, business leadsManagement reviewApproval minutes, review record
AI acceptable use policyAI governance group (or CISO where none exists)HR, legal, privacy, worker representativesAcknowledgement, training gate, monitoring, disciplinary processAcknowledgement records, training completion, case files
AI security policyCISOAI platform lead, enterprise architecture, procurement, privacyArchitecture review, release gate, auditReview records, exceptions, audit reports
Approved tools registerAI governance group, operated by securityProcurement, privacy, legalAccess provisioning only for approved tools; blocking or coaching for othersRegister history, assessment records
ExceptionsRisk owner at the level set by the risk appetiteCISOTime-limited approval with compensating controlsException register with expiry dates

HR should approve the consequences clause and consultation route, not the technical controls; equally, an AUP issued by security without HR and legal review often cannot be enforced.

How the documents fit together

Described as an architecture, the set has four layers and one shared record:

  1. Top: the AI governance policy sets principles, risk appetite, roles and the tiering method. It sits beside, or under, the Information Security Policy Template top-level policy.
  2. Two topic policies: the AI AUP (people) and the AI security policy (systems).
  3. Standards: AI security standards carry measurable values: credential lifetimes for agents, required log fields, pre-release test coverage, supplier assessment criteria. The AUP has no standards layer of its own; its "standard" is the data class matrix and the register.
  4. Procedures: tool request, agent onboarding, red team sign-off, incident handling, exception requests.
  5. The register: the shared record both policies point to. It holds tool status, data ceilings, owners and tier. NIST AI RMF GOVERN 1.6 asks for "mechanisms ... to inventory AI systems", and NIST AI 600-1 GV-1.6-002 asks organisations to define inventory exemptions in policy for generative AI embedded in application software, which is a governance policy decision the register then applies.

Worked scenario: one request, three documents

A sales team asks to use an AI meeting assistant that joins customer calls, transcribes them and drafts follow-up emails it can send from the salesperson's mailbox.

  • Governance policy: the tiering method rates the use. Customer personal data, external communication and an agent that can send email on a person's behalf place it in a higher tier needing AI governance group approval and a data protection impact assessment.
  • Security policy and standards: the security assessment applies the tier's baseline: SSO, admin-approved OAuth scopes limited to calendar and send-as for the named users, no vendor training on customer data, transcript retention set to the records schedule, audit logs exported to the SIEM, and a supplier assessment. The register entry is created as "approved with conditions" with a Confidential data ceiling and named owner.
  • AUP: nothing is rewritten. The existing clauses already say: use only tools in the register within their conditions, tell call participants when AI transcription is in use, review drafted emails before sending, and never connect the tool to a personal account. The salesperson's obligations come from the AUP; the tool's configuration comes from the standard.

With one combined policy naming tools and settings, this request would need a committee-approved amendment; with the split, it is a register change.

When to merge and when to separate

  • Small organisation (under about 250 staff, no in-house AI development): one AI policy with two clearly headed parts is acceptable, "Rules for staff" and "Rules for systems we buy", plus the register. Keep the staff part short enough to acknowledge separately.
  • Mid-size, buying AI and building integrations: separate AUP and AI security policy, with a combined AI standard covering identity, data and logging. Add agent clauses as soon as anyone connects an agent to business systems.
  • Large or regulated, building models and agents: AI governance policy, AUP, AI security policy, several AI standards (agent identity, model lifecycle, testing, supplier), and a separate shadow AI policy if discovery and blocking are active. Map each to ISO/IEC 42001 if you are pursuing certification; see the ISO/IEC 42001 Guide.
  • Separate AI security policy or annex? If existing standards already cover application security, identity and suppliers, add AI-specific standards instead. Create a separate policy when agent delegation, model change control and pre-release evaluation cannot be expressed in them.

Restructuring a combined AI policy

  1. Inventory the statements. Extract every "must" and "must not" from the current document into a spreadsheet and tag each as person, system, list or principle.
  2. Allocate. Person statements go to the AUP, system statements to the security policy or a standard, lists to the register, principles and tiering to the governance policy. Use the allocation table above.
  3. Rewrite for the reader. Rewrite AUP clauses in second person plain language; rewrite security clauses as control objectives with a named responsible role.
  4. Keep traceability. Record the old clause number against the new location so audit evidence collected under the old policy still maps. Auditors test the chain from requirement to evidence.
  5. Consult. Run the AUP through HR, legal, privacy and, where required, worker representatives. Run the security policy through platform and procurement leads.
  6. Pilot. Issue the AUP to one business unit with the acknowledgement flow and measure questions raised; apply the security policy to two live AI systems as a dry-run review.
  7. Cut over. Approve both, retire the combined document, and collect fresh acknowledgements. PL-4 expects people who acknowledged a previous version to re-acknowledge.
  8. Roll back if needed. Keep the combined policy available as superseded for one cycle so its rules can be reinstated if AUP consultation stalls.

Detection and measurement

  • Acknowledgement coverage: percentage of active users with access to approved AI tools who have acknowledged the current AUP version (target 100% before access).
  • Unapproved tool use: distinct unapproved AI services seen in proxy, CASB or OAuth consent logs per month, and the trend after each awareness push.
  • Register coverage: share of AI systems and agents found by discovery that have a register entry with owner and tier.
  • Security review coverage: share of production AI systems and agents with a completed review against the AI security standard for their tier.
  • Request cycle time: median days from a new tool request to a decision. A long cycle predicts shadow AI.

Common failure patterns

  • One policy doing all three jobs. Board principles, staff rules and engineering controls in one document. Staff do not read it, engineers cannot find the values and every tool change needs committee approval.
  • AUP with no technical backstop. A rule against restricted data in unapproved tools, with no consent controls or gateway inspection, relies entirely on memory. The Vercel Context.ai case shows how a single consented OAuth grant outlives the user's intent.
  • Security policy written for models only. Controls for model endpoints but nothing on agent identity, delegated access or tool permissions, so agents run on shared service accounts.
  • No consultation on monitoring. Monitoring of AI prompts introduced through the security policy without a notice in the AUP or a data protection assessment, which undermines enforcement when a case reaches HR.

Framework mapping

FrameworkRequirementAUPAI security policy and standards
ISO/IEC 42001Clause 5.2 AI policy; B.2.2 AI policy guidanceReflects the AI policy for usersReflects the AI policy for systems
ISO/IEC 42001B.9.3 objectives for responsible use of AI systemsPrimary homeSupports through oversight design
ISO/IEC 42001B.4.2 to B.4.6 resource documentation; B.10.2 and B.10.3 third partiesNoPrimary home, with the register
EU AI ActArticle 4 AI literacy (as amended by Regulation (EU) 2026/1744)Literacy measures for staff using AICompetence for operators and oversight staff
EU AI ActArticle 26 deployer obligations for high-risk systems: instructions for use, competent human oversight, input data, monitoring, logs kept at least six months, informing workersWorker information (26(7)) and user dutiesOversight assignment, data, monitoring, log retention
NIST AI RMFGOVERN 1.2, 1.6, 2.1, 6.11.2 and 2.11.2, 1.6, 2.1, 6.1
NIST AI 600-1GV-1.4-002, GV-3.2-003, GV-6.1-010 acceptable use policiesPrimary homeInforms system design limits
NIST CSF 2.0GV.PO-01, GV.PO-02, GV.RR-02, PR.AT-01, PR.AA-05GV.PO, PR.AT-01GV.PO, GV.RR-02, PR.AA-05
NIST SP 800-53 Rev. 5PL-4, PL-4(1), PS-6, AT-2, AC-20, SA-9PL-4, PL-4(1), PS-6, AT-2AC-20, SA-9
ISO/IEC 27001:2022Annex A 5.1 policies; 5.10 acceptable use of information and other associated assets5.105.1 topic-specific policy

Article 26 applies to deployers of high-risk systems. Under Article 113 as amended by the Digital Omnibus on AI (Regulation (EU) 2026/1744, in force 27 July 2026), the high-risk rules apply from 2 December 2027 for Annex III systems and 2 August 2028 for Annex I product systems, while Article 4 has applied since 2 February 2025. If you are unsure whether you are a provider or deployer for a given system, see the EU AI Act Provider vs Deployer Obligations Guide.

Practitioner checklist

  • Tag every clause in your current AI policy as person, system, list or principle, and move it to the matching document.
  • Keep the AUP short enough to read in ten minutes and get a documented acknowledgement before granting AI tool access.
  • Move tool names, data ceilings and model versions out of policy text into the register.
  • Write a data class to tool status matrix in the AUP and enforce it technically through consent controls and gateway or DLP inspection.
  • Add agent clauses to both documents: delegation rules for users, identity and scoping rules for systems.
  • Define control baselines per risk tier in the AI security standard and reference the tiering method in the governance policy.
  • Put the monitoring notice in the AUP and complete a data protection assessment before monitoring prompts.
  • Assign an owner, consultees and an enforcement route for each document, and an exception authority with expiry dates.

Standards and references

Related NHI Mgmt Group resources: AI Acceptable Use Policy Template · Agentic AI Security Policy Template · AI Governance Policy Template · Shadow AI Policy Template · AI Agent Registry vs CMDB vs IGA

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NHIMG Editorial Note
Researched and written by the NHI Mgmt Group editorial team using AI tools, under the editorial direction of Lalit Choda. Facts are drawn from the sources listed on this page and checked by our automated quality process. Last updated 14 November 2026. Spotted an error? Use our contact page.
NHI Mgmt Group, the independent authority on Non-Human Identity, IAM and Agentic AI security. nhimg.org