Phase 1: Enterprise Readiness

• Licensing: Use an eligible M365 base license (E5) plus Copilot (E7 adds adjacent controls, not more Copilot functionality).
• Identity Baseline: Enforce Entra SSO, MFA, Conditional Access, and managed-device access before go-live.
• Platform Readiness: Keep mailboxes in Exchange Online, keep M365 apps current, and allow required Microsoft endpoints and browser support.
• Auto-Deploy Risk: Review Microsoft’s Copilot app rollout settings so Copilot does not simply appear before guardrails are in place.

Phase 2: Data Boundary & Permission Hygiene 

• Oversharing Audit: Run Purview DSPM for AI and review broad SharePoint access before Copilot can ground on it.
• Safe Zones: Apply sensitivity labels, use No-AI exclusions where needed, and keep high-risk sites out of Copilot search.
• Restricted Discovery: Use SharePoint Restricted Content Discovery when a client wants Copilot without exposing all SharePoint content on day one.
• Approved Tools Only: Block unapproved plugins, browser extensions, and consumer AI paths.

Phase 3:  Compliance & Defensibility

• Audit & Logging: Enable Purview Audit so prompts, responses, and policy events are reviewable for LP, ODD, and regulatory scrutiny.
• DLP Guardrails: Block or redact MNPI, investor PII, and compensation data in Copilot interactions.
• Policy: Publish an AI acceptable-use policy with approved use cases, off-limits data, and an exception path before rollout.
• Retention: Map Copilot activity into existing retention and eDiscovery workflows.
  

Phase 4: Decide the Plan, data Boundary and Integrations

• Pilot Scope: Start with a small low-risk user group and curated libraries; don’t begin with trading, or investor data.
• Sanctioning: Sanction M365 Copilot and approved AI; monitor and block unsanctioned AI through Defender for Cloud Apps.
• Teams Governance: Set a deliberate stance on transcription and meeting AI features; several alt-invest clients are defaulting to tighter settings.
• Prompt Playbooks: Give users role-based prompts for research, IR, and recap workflows so adoption is useful, not random.
• Agentic Features: Treat Copilot Cowork and similar agentic modes as a separate decision with separate controls, not a default extension of chat Copilot.

If you cannot explain where the data goes, who can reach it, and what gets logged, you are not ready for tenant wide Copilot.