Springing off the linked NIST thread;

I'm in a 70 person environment acting as ECO/CUI specialist and we are tackling the Acceptable Use policy with respect to AI and covering proprietary, customer confidential, EAR controlled, ITAR controlled, CUI data, and supportive engineering.

Our export control program has morphed into an export and Data Handling control program which requires the classification of data types at ingestion and creation.

Access is then restricted (procedurally) based on the US person status, business need and data type.

Currently AU policy is the only barrier to use of the AI types, with each data type having the 'allowable' AI spelled out. Published specs available on the open internet = use any AI in any environment. Controlled Data that doesn't meet EAR/ITAR/CUI requirements = company approved AI environments. Data meeting the controls of EAR/ITAR/CUI =GCC+/FEDRAMP AI environments or on-prem AI with the proper configuration and access controls to prevent the model from contributing that knowledge outside the org while still being able to access the internet for data. Currently using Preveil for secure file transfer and MS network credentials/group permissions for controlled data on the local network. No intent to move to an MSP and just grow the internal IT team to support as things develop.

With this 'start with the data as it's received and work your way out' method, there's an active situation I need to resolve:

One business unit has become rather entrenched in using GPT and/or non-GOV Copilot to scan and summarize emails and track requests for quote.  As I'm sure most of you have seen, you can't control what people send you (I had a drawing loaded with CUI flows and distribution statements come in standard email from someone that should not have had it to begin with).  In this case, due to the automatic perusal of emails, that CUI would be reviewed by a non-FEDRAMP/non-GCC+ agent with no human intervention.  That's a deemed export and no bueno.

Ideally, we'd have something compliant labeling email coming in - I know the Preveil email client will automatically flag and encrypt outgoing messages, but is there something similar that will flag incoming messages?  That would make it at least reasonable to find a path to exclude those from this generalized incoming email scan.  Secondarily, it would help users that are a few heartbeats away from me that don't typically have to handle this sort of data recognize it when it comes in.

  
I've explained internally that either the data has to be categorized upon receipt prior to being loaded into a public AI bucket, or the AI bucket needs to be upgraded to hold the most stringent data types.  Unfortunately we're at an impasse where the system's already been built (outside my purview) and there's resistance to change, so seeking an incoming filter seems to be the less painful approach on my part.  TIA

70 person company, largely compliant, how to handle incoming email, AI