Include contractors and outsourced teams whenever they use AI for your work or handle information under your control. Agree what each party may do, which tools and accounts support it, who checks the result, and who approves a change. An employee policy can establish your expectations, but an external service also needs an agreed way to carry them out.
For a service owner, the useful question is whether the client and supplier can describe the same permitted task. A supplier's general permission to use AI does not establish permission to put your customer records into its chosen service. Your approval of one drafting task does not authorize another subcontractor, a new data source or automatic replies.
Cover the working arrangement
Start with the people and services involved, including agency staff, individual consultants, outsourced operations and relevant subcontractors. Ask how AI is used in delivery, even when the purchase is described as customer support, translation or document preparation.
The UK Cabinet Office's procurement transparency guidance makes that distinction explicitly. Within its UK central-government scope, it recognizes AI use in services not sold as AI and suggests disclosure to inform due diligence or contractual changes. It does not prescribe a universal ban on supplier AI use.
Distinguish the actual arrangements:
- A contractor uses your work account. Your technical team may control access, but the contractor still needs task permissions, guidance and a reachable owner.
- An agency uses its own service. Establish the applicable account, processing arrangement and controls before client information enters it. An employee's approval for a different account does not transfer automatically.
- A shared service supports several clients or business units. Agree which instructions and information apply to each engagement. A common service must not silently pool material whose reuse has not been authorized.
Use the employee acceptable-use guide for the underlying rules. Then resolve how those rules reach the external people doing the work, including replacements who join after the agreement is signed.
Agree one permitted task across both organizations
Suppose Claire Bennett runs enquiries for a professional training provider. Sam Taylor leads the agency preparing replies about its courses. They propose using AI to draft answers from the provider's public course catalogue and an approved booking-policy document.
The first authorization can be narrow. Agency staff may prepare a draft in the agreed work service using those sources and an enquiry prepared without learner details. They may not upload learner histories or payment records, confirm a place, issue a refund or send automatically. An authorized person checks each reply before it leaves the agreed process.
Make that working record specific enough to resolve an ordinary question:
| Decision | What Claire and Sam need to agree |
|---|---|
Permitted information | The current course catalogue, approved booking policy and the allowed form of an enquiry. Name excluded records too. |
Tool and account | The actual service, work account, enabled connections and responsible access owner. |
Acceptable output | A checked draft that preserves unknown availability and does not invent prerequisites or dates. |
Authority to act | Who can send the reply, confirm a booking or make a financial commitment through the existing process. |
Continuing responsibility | Who maintains the sources, answers questions and receives proposed changes or concerns. |
Keep task approval separate from service assessment. The client may agree that drafting replies is useful while still withholding permission for the agency's proposed tool or data handling. Use the vendor evaluation guide to investigate those service claims with the appropriate technical, information and commercial owners.
Give each responsibility a reachable owner
Claire owns the client's service decision. Sam owns delivery within the agency's agreed scope. Neither role replaces the specialist authority needed to approve information handling, access or contractual terms. Record who makes those decisions and how the other party reaches them.
Australia's National AI Centre implementation guidance includes contractors and third-party providers when assigning accountability. It also calls for defined authority and competence, and clear responsibilities across the AI supply chain. This is governance guidance, not evidence that a particular responsibility chart prevents failures.
For Claire and Sam, the important relationship looks like this:
One course-enquiry task across two organizations
Claire and Sam agree the scope before agency staff draft course replies.
Claire defines the permitted work
Obtain the relevant owners’ approval for the sources, account and actions. Name who can resolve an unknown course date or availability.
Sam equips the operator and reviewer
Use the agreed sources and account. Check dates, prerequisites and missing availability before the authorized reply. Prepare replacements for the same scope.
Return the affected use for a decision
A new translation service or subcontractor introduces another handling arrangement. Keep that use on hold while the responsible owners assess and authorize it.
The reviewer needs more than a name beside a task. Give that person the current catalogue, booking policy, permitted account and a route for unresolved questions. If a course date conflicts with another source or availability is unknown, the reviewer must be able to hold the reply and obtain an answer.
Sam should also know who covers that role when the usual reviewer is absent. A delivery target cannot supply missing authority. If the agreed reviewer or approved service is unavailable, use the established non-AI route or pause the affected work under the service arrangement.
Reconcile client terms and downstream use
Ask both parties to identify restrictions that could change the proposal. These may come from client commitments, confidentiality, personal-information handling, intellectual property or the supplier's own agreements. Refer a conflict to the responsible commercial, legal or information owner before using the material in the disputed way.
A practical account from construction adviser Grant Fuellenbach makes the account-level question tangible. In his October 2026 guidance, he asks teams to check the account they actually use and their client contract before sharing documents. He sells AI implementation services; this is practitioner advice rather than a verified rollout result. A paid subscription alone does not answer the permission question.
Check the direction of sharing too. In a March 2026 public design discussion, a Reddit user described adding a restriction after clients returned concepts that had been put through AI. Another Reddit user described the difficulty of explaining the resulting work, while replies questioned the practical response to a violation. The businesses and outcomes were unverified. The useful question is mutual: what may your company do with a supplier's drafts, as well as what may the supplier do with yours?
Have the agreement address the handling that matters for this engagement:
- Whether information may be retained, reused for another client or used to train or improve an AI service.
- Which other organizations may receive it, including proposed subprocessors or subcontractors.
- How material changes are notified and which uses wait for a new decision.
- What records, access removal, return or deletion are required when a person or service leaves.
For a UK personal-data example, the ICO's AI contracts and third-parties guidance calls for assessing processing roles across the supply chain and documenting responsibilities. Its expectations include documented instructions, authorization and contracts for subprocessors, and end-of-contract arrangements. The page was under review when checked in October 2026. Have your privacy and legal owners confirm the current applicable position; an agency is not automatically a processor for every activity.
A contract records obligations. It cannot, by itself, show that the right account is in use, that access is limited as agreed or that the next agency recruit received the instructions.
Rehearse the handoff and a meaningful change
Before the course-enquiry work starts, ask the people who will actually operate and review it to demonstrate the route with approved synthetic material. This checks whether the arrangement is usable. It does not establish reliability across every future enquiry.
- Find the permitted route. An agency colleague locates the current instructions, signs into the agreed account and identifies the sources they may use.
- Handle a missing fact. Use an enquiry asking for a place on a course whose availability is not confirmed. The draft and reviewer should preserve that uncertainty and use the named help route.
- Test a proposed change. Sam proposes sending enquiries to a translation service or another subcontractor. Identify who assesses the changed handling and keep that affected use on hold until the required decisions are made.
- Hand over or leave. Show how a replacement receives task-specific guidance, and how access and records are handled when someone stops doing the work.
Keep training responsibilities explicit. The client can explain its sources, restrictions and decisions; the agency can arrange relevant preparation and supervision for its people. Agree who supplies each part and how replacements receive it. A course-completion record alone does not establish that someone can find the correct account or identify an unsupported answer.
Give external staff a usable reporting route too. If someone suspects restricted information went to an unapproved service, they should know how to stop further sharing and contact the responsible team. The client and agency need an agreed receiving handoff, including outside ordinary working hours where the service requires it. Use the incident and near-miss guide to define intake and triage rather than asking the reporter to prove the full cause first.
Take one outsourced task to both owners. Resolve any disagreement about permitted inputs, the checking responsibility and approval of a change before expanding the work. Keep the agreement and the working instructions consistent as the service evolves. For the wider operating arrangement, use the tools and workflows guide.
Questions about external teams and AI policy
Does the AI policy apply to every contractor?
Define the policy's scope around work performed for your organization, information handled and AI activities involved. Include relevant contractors and outsourced teams rather than assuming their employer's policy covers the engagement. A contractor doing no AI-related work may need different instructions from an agency drafting customer replies. Identify the actual activity and agree its permitted scope.
Can an agency use its own paid AI account?
Only where the relevant client and supplier owners have approved that actual arrangement for the proposed work and information. Payment or a familiar product name does not establish applicable terms, suitable settings or client permission. Record the account, permitted sources, connections and responsible access owner. Resolve any service-assessment gap before entering client information.
Does approving an agency authorize its subcontractors too?
Do not infer that from the agency's approval alone. Check the agreement, proposed downstream handling and applicable obligations. Identify which subcontractors or other services are covered, how additions are notified and what authorization is required. Hold an uncovered use while the responsible owners decide it. The translation example shows how an apparently small delivery change can introduce another recipient.
What if the client and supplier policies conflict?
Pause the affected use and take the specific conflict to the owners responsible for the agreement and information. An individual worker should not choose which obligation to ignore. Describe the task, material, proposed service and conflicting instructions, then obtain a documented decision or an alternative permitted route. Do not assume that signing one party's policy cancels another commitment.
What should we check before external staff start?
Ask the actual operator and reviewer to find the current instructions, use the permitted account, identify excluded information and handle an incomplete answer. Confirm where questions and concerns go, who covers absence, and what happens when the team or service changes. Keep the rehearsal findings and unresolved permissions distinct. A successful exercise supports that observed task; it does not authorize broader data access or automatic action.
