Governance Operating Calendar
Recurring governance activities for maintaining M365 Copilot governance controls in financial services environments. This calendar defines the cadence, owners, and deliverables for each activity.
Disclaimer
This playbook is provided for informational purposes only and does not constitute legal or regulatory advice. Consult legal counsel for specific compliance requirements.
Monthly Activities
| Activity | Responsible Role | Target Week | Deliverable |
|---|---|---|---|
| Review Copilot usage reports and adoption metrics | M365 Global Admin | Week 1 | Monthly usage report |
| DLP violation review and false positive analysis | Purview Compliance Admin | Week 1 | DLP effectiveness summary |
| DSPM for AI oversharing assessment review | Information Protection Lead | Week 2 | Oversharing status report |
| Sensitivity label coverage and adoption metrics | Information Protection Lead | Week 2 | Label coverage report |
| Insider Risk Management alert triage summary | Security Operations | Week 2 | IRM monthly summary |
| License utilization review and optimization | M365 Global Admin | Week 3 | License optimization recommendations |
| Guest and external user access review | Identity Admin | Week 3 | Guest access audit |
| RSS allowed site list review | SharePoint Admin | Week 3 | RSS change requests (if any) |
| Copilot extension and plugin inventory review | Security Lead | Week 3 | Plugin change detection report |
| Training compliance and completion report | Training Lead | Week 4 | Training completion rates |
| Governance committee meeting | AI Governance Lead | Week 4 | Meeting minutes and action items |
| Update risk register with monthly findings | Risk Manager | Week 4 | Updated risk register |
Quarterly Activities
| Activity | Responsible Role | Quarter Month | Deliverable |
|---|---|---|---|
| Compliance review meeting (full committee) | Compliance Officer | Month 1 | Quarterly compliance status report |
| Control effectiveness assessment | Security Lead | Month 1 | Control effectiveness scorecard |
| Comprehensive permission model audit | Identity Admin | Month 1 | Permission audit report |
| Vendor risk reassessment (Microsoft AI services) | Risk Manager | Month 1 | Updated vendor risk assessment |
| DLP and information protection policy updates | Purview Compliance Admin | Month 2 | Policy change documentation |
| Sensitivity label taxonomy review | Information Protection Lead | Month 2 | Taxonomy update recommendations |
| Conditional Access policy review | Identity Admin | Month 2 | CA policy effectiveness report |
| Information Barrier policy verification | Compliance Officer | Month 2 | Barrier compliance report |
| Training content refresher and update | Training Lead | Month 3 | Updated training materials |
| License utilization and cost optimization | M365 Global Admin / Finance | Month 3 | License optimization report |
| Information architecture health review | SharePoint Admin | Month 3 | Architecture health report |
| Compliance evidence package update | Compliance Officer | Month 3 | Updated evidence package |
| Governance committee strategic review | AI Governance Lead | Month 3 | Quarterly governance report |
Semi-Annual Activities
| Activity | Responsible Role | Timing | Deliverable |
|---|---|---|---|
| Regulatory landscape review and impact assessment | Compliance Officer | H1, H2 | Regulatory change impact report |
| Governance framework update and version review | AI Governance Lead | H1, H2 | Framework update recommendations |
| Vendor risk full reassessment (Microsoft AI) | Risk Manager | H1, H2 | Comprehensive vendor risk report |
| Tabletop exercise: AI incident response | Security Operations | H1, H2 | Exercise after-action report |
| Internal audit of Copilot governance controls | Internal Audit | H1, H2 | Audit findings report |
| Copilot acceptable use policy review | Legal / Compliance | H1, H2 | Updated AUP (if changes needed) |
Annual Activities
| Activity | Responsible Role | Timing | Deliverable |
|---|---|---|---|
| Board-level AI governance review and reporting | CISO | Q1 | Board governance presentation |
| Comprehensive governance audit | Internal Audit / External | Q1 | Annual audit report |
| Training program renewal and effectiveness assessment | Training Lead | Q2 | Annual training report |
| FINRA Rule 3120 testing of supervisory controls | Compliance Officer | Q2 | FINRA 3120 testing report |
| Full data classification and labeling review | Information Protection Lead | Q3 | Classification audit report |
| Copilot governance framework annual revision | AI Governance Lead | Q3 | Framework version update |
| Regulatory change comprehensive assessment | Compliance Officer | Q4 | Annual regulatory update report |
| Budget and resource planning for next fiscal year | AI Governance Lead | Q4 | Governance budget proposal |
Activity Detail Templates
Monthly Governance Committee Meeting Agenda
- Review of previous action items (5 min)
- Copilot usage and adoption metrics (10 min)
- Active user count, interaction volume, application breakdown
- Adoption trends and barriers
- DLP and security incident summary (10 min)
- DLP violation count and trend
- Security alerts and resolutions
- Insider risk signals (if any)
- Oversharing and data hygiene update (5 min)
- DSPM findings and remediation progress
- Label coverage metrics
- Policy change requests and approvals (15 min)
- Pending policy changes requiring committee vote
- Impact assessment for proposed changes
- Compliance and regulatory updates (10 min)
- Regulatory changes affecting Copilot governance
- Upcoming examination activities
- Risk register review (5 min)
- New risks identified
- Remediation progress on open items
- Action items and next steps (5 min)
Quarterly Compliance Review Meeting Agenda
- Quarterly governance metrics dashboard (15 min)
- KPIs: DLP match rate, label coverage, audit log completeness, training completion
- Trend analysis quarter-over-quarter
- Control effectiveness assessment (20 min)
- Controls tested and results
- Controls requiring remediation
- Compensating controls in place
- Risk register and remediation progress (15 min)
- Open items and aging
- Escalations for overdue items
- Regulatory landscape updates (15 min)
- New or proposed regulations affecting Copilot
- Examination findings from industry peers (if available)
- Regulatory guidance updates
- Strategic decisions and policy updates (20 min)
- Major policy changes requiring approval
- Architectural or tooling decisions
- Next quarter planning (15 min)
- Activities scheduled per operating calendar
- Resource requirements
- Key milestones
FINRA Rule 3120 Annual Testing Checklist
| Test Area | Test Description | Pass/Fail | Evidence |
|---|---|---|---|
| Supervisory procedures | Copilot communications are covered by written supervisory procedures | ||
| Communication review | Copilot-assisted communications are reviewed per supervision program | ||
| Record retention | Copilot interaction records retained per required periods | ||
| Information Barriers | Chinese Wall barriers enforced for Copilot access | ||
| Training | Personnel received training on Copilot governance requirements | ||
| Reporting | Supervisory reports include Copilot governance metrics |
Calendar Integration
To implement this operating calendar:
- Create a shared calendar in Teams or Outlook for the governance committee
- Set recurring appointments for each activity at the specified frequency
- Assign owners to each recurring appointment with agenda and deliverable expectations
- Configure reminders 7 days before each deliverable due date
- Track deliverable completion in the governance committee meeting minutes
Review this calendar annually and update based on organizational changes, regulatory updates, and governance maturity progression.
FSI Copilot Governance Framework v1.2.1 - March 2026