Control 1.3: SharePoint Content Governance and Permissions
Control ID: 1.3 Pillar: Security Regulatory Reference: GLBA 501(b), SEC Reg S-P, FINRA 4511 Last UI Verified: January 2026 Governance Levels: Baseline / Recommended / Regulated Last Verified: 2026-02-03
Objective
Ensure AI agents only access authorized SharePoint content through proper permission governance, sensitivity labels, and access controls to prevent inadvertent exposure of sensitive customer information.
Why This Matters for FSI
- GLBA 501(b): Requires safeguards for customer NPI stored in SharePoint
- SEC Reg S-P: Mandates privacy safeguards for customer records in document libraries
- FINRA 4511: Requires books and records with appropriate access controls and audit trails
- SOX 302/404: Requires segregation of duties for financial document access
- Oversharing Prevention: Stops accidental exposure of sensitive data through AI responses
Control Description
SharePoint is the primary knowledge source for most Copilot Studio agents. This control establishes governance over SharePoint content to ensure agents access only authorized data. The control implements:
- Tenant-Level Sharing Controls - Restrict external sharing organization-wide
- Site-Level Permissions - Configure least-privilege access for agent knowledge sources
- Sensitivity Labels - Apply classification labels to sites and document libraries
- SharePoint Advanced Management controls - Additional restriction layer including Restricted Content Discovery (RCD) and Data Access Governance reports
- Access Reviews - Periodic recertification of permissions
Properly configured SharePoint governance restricts agents from accessing or returning sensitive customer information beyond their authorized scope.
Key Configuration Points
- Configure tenant-level sharing to "Only people in your organization" for FSI
- Remove "Everyone" and "Everyone except external users" groups from agent knowledge sites
- Apply sensitivity labels to sites and libraries (Confidential-FSI, Highly Confidential)
- Enable SharePoint Advanced Management controls (RCD, Data Access Governance) for enterprise-managed agent data sources - see Control 4.1
- Configure quarterly access reviews for agent knowledge site permissions
- Create dedicated sites for agent knowledge with restricted permissions
Zone-Specific Requirements
| Zone | Requirement | Rationale |
|---|---|---|
| Zone 1 (Personal) | Site owner discretion; annual access reviews; labels recommended | Low risk, personal data scope |
| Zone 2 (Team) | Partner domains only; semi-annual reviews; labels required (Internal+) | Shared data requires accountability |
| Zone 3 (Enterprise) | No external sharing; quarterly reviews; labels required (Confidential+); IAG enabled | Customer-facing, regulatory examination risk |
Roles & Responsibilities
| Role | Responsibility |
|---|---|
| SharePoint Admin | Configure tenant and site settings, manage permissions |
| Site Collection Admin | Manage site-level permissions and labels |
| Purview Compliance Admin | Configure and publish sensitivity labels |
| AI Governance Lead | Approve agent data source sites |
| Compliance Officer | Review access audit evidence |
Related Controls
| Control | Relationship |
|---|---|
| 1.5 - DLP & Sensitivity Labels | Labels must be created before applying to sites |
| 4.1 - SharePoint IAG | Advanced content restriction for enterprise sites |
| 4.2 - Site Access Reviews | Periodic recertification of permissions |
| 4.4 - Guest Access Controls | External user management |
| 1.14 - Data Minimization | Agent scope restrictions |
Implementation Playbooks
Step-by-Step Implementation
This control has detailed playbooks for implementation, automation, testing, and troubleshooting:
- Portal Walkthrough — Step-by-step portal configuration
- PowerShell Setup — Automation scripts
- Verification & Testing — Test cases and evidence collection
- Troubleshooting — Common issues and resolutions
Verification Criteria
Confirm control effectiveness by verifying:
- Tenant-level sharing is restricted to "Only people in your organization" (or more restrictive)
- Agent knowledge sites have no "Everyone" or "Everyone except external users" groups
- Sensitivity labels are applied to all agent data source libraries
- Agent cannot retrieve content from excluded/unauthorized sites
- Access reviews are scheduled and notifications are being sent
Additional Resources
- Microsoft Learn: SharePoint Site Permissions
- Microsoft Learn: SharePoint Sharing Settings
- Microsoft Learn: Sensitivity Labels for SharePoint Sites
- Microsoft Learn: SharePoint Advanced Management
- Microsoft Learn: Access Reviews Overview
Updated: January 2026 | Version: v1.2 | UI Verification Status: Current