{"resourceId":"king-county-wa-records-guidance-copilot-chat-30-day-storage-not-legal-retention-202610","versions":[{"version":"external-3c704b545575033e6b1abd2b77df62360e35b057da7c7d616b35212e473cd9a9","resource":{"id":"king-county-wa-records-guidance-copilot-chat-30-day-storage-not-legal-retention-202610","title":"King County, Wash., records guidance (10/2026): Copilot Chat is the county's approved generative AI tool, its enterprise storage setting is 30 days, and non-transitory prompts and results must be captured into county records","organization":"King County Records and Information Management Program (CRIMP)","sector":"Local government","geography":"King County, Washington, United States","publishedAt":"2026-10-26","publicationDate":"2026-10-26","eventDate":null,"sourceName":"King County","sourceLabel":"Records Management Guidance: Generative AI (3-page PDF)","sourceUrl":"https://cdn.kingcounty.gov/-/media/king-county/depts/executive-services/records-management/rm/rm-guidance-generative-ai.pdf","evidenceClass":"standards-guidance","outcomeClass":"cautionary","topics":["governance-procurement","data-security","operating-model"],"finding":"King County's records programme says Copilot Chat is the county's approved enterprise generative AI tool. Both prompts and results are potentially subject to disclosure under RCW 42.56 and retention under RCW 40.14.010. The enterprise storage setting for Copilot Chat records is 30 days, and content not saved before then cannot be retrieved. The guidance says this setting is not the same as legal retention. Transitory uses (quick edits, brainstorming, search-like questions) need no action. Non-transitory uses (substantive changes, decision support, legal or compliance guidance, anything public-facing) must be copied into other county records and filed under the right schedule (for example 6, 3 or 2 years). Export to Word does not include prompts.","sledRelevance":"A large US county has documented the gap between Copilot Chat's default storage and public-records retention law, with a manual capture procedure. Any SLED agency rolling out Copilot Chat under state records law faces the same gap.","evidence":"A primary county guidance document with legal citations, retention examples and a step-by-step capture procedure. It is guidance, not an audit; it reports no data on how often staff capture records.","architectureImplications":"The county relies on a 30-day storage setting plus manual copy-and-paste or Export to Word into Word, email or Content Manager. There is no automated capture of non-transitory Copilot records in the guidance.","governanceImplications":"Records responsibility sits with each user deciding whether a use is transitory. That puts a judgement call on every employee and makes training and spot checks important.","securityPrivacyImplications":"Short storage limits exposure, but content may still be discoverable for a few days after 30 days. Losing non-transitory records is a compliance risk under state law.","caveats":"Guidance only; no compliance data. The document is dated 10/2026; the day (Oct. 26) comes from PDF creation metadata. The retention periods are simplified, per the document. Microsoft retention capabilities beyond the 30-day setting are not discussed, so this is the county's chosen configuration, not a product limit.","streamIds":["microsoft","local-government"],"roles":{"sales":"Sales framing: King County has made Copilot Chat its approved tool and then found a records problem. Its 30-day storage setting does not meet legal retention for non-transitory use, so staff must capture records by hand. This is a concrete, bounded need across Washington and other public-records states. A records-and-retention design engagement is credible. Claims that Copilot is compliant with state records law out of the box are not supported. Ask who carries the records risk today and how they would know if records were lost.","engineering":"Engineering framing: the county's design is a 30-day storage setting plus manual export. Engineers should evaluate whether Purview retention policies for Copilot interactions, labels or eDiscovery holds can capture non-transitory records more reliably than copy-and-paste. Note that Export to Word drops prompts, which the guidance says are records too. Any design must match retention schedules by content and function, not one blanket period, and must keep prompts and results together for public-records searches.","delivery":"Delivery framing: the guidance moves the retention decision to every Copilot user. Delivery should pair it with short training using the county's transitory and non-transitory examples, a clear capture path into SharePoint, Teams or Content Manager, and periodic sampling to check that decision-support uses are being saved. Track records-request outcomes involving AI content. Coordinate records management, IT and agency records officers so the 30-day setting and legal schedules stay aligned as Copilot features change."},"roleDetails":{"sales":{"customerProblem":"An agency has approved Copilot Chat but its default storage does not satisfy public-records retention for substantive uses.","stakeholders":["Records manager / records officers","CIO and IT","Agency attorneys","Public disclosure officers","Department heads"],"discoveryQuestions":["How do staff currently decide whether a Copilot use is transitory?","How would you find Copilot prompts for a public-records request today?","Have you configured Copilot retention beyond the default?","Who audits whether non-transitory AI records are captured?"],"valueHypothesis":"A retention design that captures non-transitory Copilot records with less manual effort may lower records-compliance risk.","potentialEngagement":"A bounded records-and-retention review of Copilot Chat, with a recommended Purview configuration and training.","unsupportedClaims":["That Copilot meets state records law by default","That manual capture is happening reliably","Any reduction in disclosure workload"]},"engineering":{"fit":"Strong fit for any SLED tenant subject to public-records retention schedules.","architectureIntegration":"Copilot Chat storage settings, Purview retention for Copilot interactions, eDiscovery, and records repositories such as SharePoint or Content Manager.","prerequisites":["Inventory of retention schedules that AI use could touch","Current Copilot storage configuration","Records repository integration"],"constraints":["Retention varies by content and function, not tool","Export to Word omits prompts","State public-records statutes differ"],"security":"Shorter storage limits exposure, but holds and retention must preserve non-transitory records and support disclosure searches.","proofOfValue":["Test whether a configured retention policy keeps prompts and results together","Run a sample disclosure search for Copilot content older than 30 days"]},"delivery":{"work":"Align Copilot Chat storage with records schedules and train staff to capture non-transitory AI records.","dependencies":["Records programme sign-off","IT configuration change","Legal review of disclosure process"],"ownership":"County records programme with IT; agency records officers for local compliance.","skillsAdoption":"Short training built on the guidance's transitory and non-transitory examples, plus job aids for capture.","governanceCheckpoints":["Records programme approves the retention configuration","Training delivered before broader rollout","Quarterly capture sampling"],"acceptanceCriteria":["Proposed: sampled decision-support Copilot uses are captured at least 90% of the time","Proposed: disclosure searches return Copilot prompts and results together","Proposed: zero confirmed losses of non-transitory AI records in a review period"],"risks":["Users misclassify uses as transitory","Manual capture skipped under time pressure","Feature changes alter storage behaviour"]}},"retrievedAt":"2026-11-02T14:37:13Z","enrichedAt":"2026-11-02T14:41:07Z","enrichmentBasis":"retrieved source","accessibilityWorkforceImplications":"Staff must learn to classify AI use as transitory or not, and to capture prompts manually, since Export to Word omits them.","procurementImplications":"Agencies buying Copilot should budget for records configuration and training, not only licences.","operatingModelImplications":"Records management (CRIMP), KCIT and each agency share ownership; the user is the first-line decision maker on retention.","sourceVerification":{"openedUrl":"https://cdn.kingcounty.gov/-/media/king-county/depts/executive-services/records-management/rm/rm-guidance-generative-ai.pdf","referenceExcerpt":"Content is not retrievable if it has not been saved or captured the content before the end of the 30-day period.","promptVersion":"sled-research-v4.0","model":null,"basis":"agent-reported inspection"}}}]}