Iowa Counties Warn Workers That ChatGPT Keeps Their Files

Johnson County IT director Bill Horning is warning Iowa workers that a ChatGPT polish of a county email leaves that private data inside the model. Several counties are writing rules on how civic staff may use AI, and Horning wants those uses written down.

Those clerks work in a state that already helped train GPT-4 next to cornfields west of Des Moines, and that still keeps adding Microsoft, Google and Meta campuses. The memo and the map do not match.

Once County Data Goes In, It Stays

Horning’s example is ordinary office work. A staffer asks ChatGPT to smooth an email. Whatever sat in that draft, names, addresses, a case note, a dollar figure, is now part of the tool’s store, he said. You cannot later tell the model to forget it.

AI tools are a great assistance in doing things, but we can’t just put data out there. AI learns from being fed information. So you put county data in there, it has that county data going forward. You can’t just say, ‘Oh, erase everything I told you.’ It doesn’t work that way. Once it’s there, it’s there.

Bill Horning, Johnson County IT director

He wants a paper trail when someone does use a tool. Johnson County staff may soon have to report if they used AI and how. The point, he said, is review after something goes wrong, not a trophy wall of prompts.

WHAT HORNING WANTS LOGGED

• The tool: Which product ran the job, including ChatGPT, Copilot or Gemini.
• The parameters: What settings, filters or custom instructions the worker applied.
• The purpose: What task the tool was asked to do, in enough detail to reconstruct the session.
• The aftermath: Enough extra detail that, if an incident lands later, the county can walk the steps again.

That review load matches the hours spent correcting AI output in other workplaces, where the cheap draft still needs a human pass. Horning is building the file that pass would need. He also said the rules matter more as AI slips into software counties already pay for, including Microsoft Copilot and Google Gemini.



The Same Counties Host the Machines

Horning named Black Hawk, Pottawattamie, Sioux and Woodbury as counties that have already written their own guidelines. Pottawattamie’s board approved its policy in May 2026. Chief information officer David Bayer said talks started the year before, and that every employee will sit through in-person and online training on the rules, the tools and how to document use.

Pottawattamie is also Google country. The company’s Council Bluffs campus sits in that county. Johnson County, Horning’s own shop, voted in November 2025 to freeze rezoning, subdivision, site-plan and building-permit work for data centers in unincorporated land. The same local governments are telling clerks not to feed models and, in the next hearing, arguing over the buildings that run them.

Microsoft president Brad Smith said in 2023 that GPT-4 was “literally made next to cornfields west of Des Moines,” and that it was “really made in Iowa.” On Sept. 8, 2026, the Energy Department announced a $1.9 billion loan to restart the 615-megawatt Duane Arnold nuclear plant in Linn County, a project tied to power for a Google data center. Iowa shops already tell clients the staff is inside ChatGPT, Copilot, Gemini and Claude, with or without a written policy. The live argument across Iowa towns is still whether to host the plants, not whether a clerk may paste an email.

IOWA’S TRACKED DATA CENTER BUILD

• 71 sites: A U.S. data-center map updated in August 2026 counts 71 tracked Iowa facilities and projects.
• 6.2 GW: Reported or announced power across those records totals 6.2 GW.
• 47 running now: The same tally lists 47 operational sites, 8 under construction and 16 planned.
• The tenants: Microsoft leads that map with 8 records, then Google with 6 and Meta with 3.

The paste-it-in habit is not only a county-clerk problem. It has already shown up in farm offices already running ChatGPT on desk work rather than on field sensors, which is the same split Horning is trying to police in a courthouse hallway.

Black Hawk Built Three Tiers Instead of a Ban

Black Hawk County did not try to outlaw the tools. Supervisors adopted a three-tier generative AI policy on Sept. 23, 2025, and told the county AI committee to review it every six months. Use is voluntary. Department heads may shut it off in their own shops.

Tier 1 covers public tools such as ChatGPT, Copilot and Gemini, but only for work with no personal data, health data, card data or other confidential files. Staff may use those tools without a special ticket once they finish an awareness course, and they must check the output before it goes official. Tier 2 is county-licensed software such as Microsoft 365 Copilot or Google Vertex AI, and it allows limited sensitive data only if the contract bars the vendor from training public models. Tier 3 is on-site or private-cloud systems for sheriff data, public-health files and anything else that has to stay inside a system built for that duty. No public chatbot may touch that layer.

Pottawattamie used the same three-bucket shape. Bayer described tier one as a “glorified Google search” with no sensitive data and no county license, tier two as licensed tools handed out for harder jobs, and tier three as tightly held analytics on sensitive files. He told staff to keep criminal-justice data, Social Security numbers, names, addresses and phone numbers out of programs such as ChatGPT.

IOWA AI RULES BY GOVERNMENT BODY

Body	Status	Core limit	Date
Iowa executive branch	In force	Free tools need written DOM approval; personal accounts banned	March 31, 2025
Black Hawk County	Adopted	Three tiers by data sensitivity; public chatbots stay off PII	Sept. 23, 2025
Pottawattamie County	Adopted	Three tiers plus required staff training	May 2026
Johnson County	Drafting	Staff may have to report if and how they used AI	2026
Iowa courts	Adopted, not yet live	No case data in a tool the committee has not approved	Jan. 1, 2027

Sioux and Woodbury have guidelines as well, Horning said. Their texts were not in the public packets reviewed for this story, so the table sticks to rules that can be read in full.

What Microsoft Promises Inside Copilot

Horning is right about consumer ChatGPT. A free chat window is a vendor’s product, not a county system, and the company’s consumer terms have never been a records vault. The licensed path is a different contract.

Microsoft’s enterprise Copilot terms say prompts, responses and data pulled through Microsoft Graph are not used to train foundation models. The company also says prompts are not used to train those models in Copilot Chat, and that tenant data stays isolated, encrypted at rest and in transit. Web queries still leave that bubble. Copilot can send a short search string to Bing with user and tenant identifiers stripped, and that path runs under a different privacy statement.

Black Hawk’s Tier 2 is written around that split. The county will put limited sensitive data into a licensed Copilot or Vertex account only when the contract says the vendor cannot train public models on it. The state goes further for executive-branch staff: freely available tools are banned unless the Department of Management signs off in writing. Personal AI accounts cannot be used for work at all.

The leak Horning described is the unpaid window a clerk opens in a browser. The harder problem he named is the Copilot already sitting in Word and Outlook, which is why a total ban on “AI” does not survive contact with the software budget.

AI Use Logs Can Become Public Records

Black Hawk put the records problem in writing. “Records generated or stored by AI vendors may be subject to public records requests,” the policy says. That sentence points at Iowa’s public records law, Chapter 22, which treats as a public record any document, tape or other information stored or preserved in any medium of or belonging to a county. Emails and texts already count. A prompt log stored to satisfy Horning would count too, unless a listed exemption applies.

The Iowa Public Information Board has also said a government body does not have to invent a new record that was never stored. Custom math on a database is not an existing file. A saved AI-use form is. Counties that order staff to document every Copilot pass are creating files a requester can later ask to see, including the prompt, the tool and the reason. Confidential pieces can still be withheld under Chapter 22’s exceptions. The rest of the log is a record.

That is the quiet cost of Horning’s audit trail. It helps after a bad output. It also leaves a new stack of paper, or a new folder in a drive, that did not exist when the clerk just rewrote the email by hand.

Iowa Courts Hold Off Until 2027

The judicial branch took longer and drew a harder line around case files. The state court administrator set up an Artificial Intelligence Working Group on Aug. 28, 2025, with Justice Christopher McDonald as chair. Chief Justice Susan Larson Christensen signed the order adopting Chapter 27 of the Iowa Court Rules on July 21, 2026. The Chapter 27 rules take effect on Jan. 1, 2027.

Rule 27.106 says a judge or an adjudicative assistant must not put judicial case information into an AI tool unless the branch committee has approved that tool for confidentiality, security and reliability. Rule 27.104 says a judge must keep independent decision-making and must not hand the work product of a tool the last word. Factual and legal sources in that work product have to be checked by a person before they go into a ruling.

Until that date, the courts are still in the study-and-approve phase. County clerks are already being told to log ChatGPT. Judges will get a committee list of allowed tools, and anything off that list stays away from the case file.

State Workers Already Face a Harder Line

Iowa’s March 2025 generative AI policy bound executive-branch staff and contractors on March 31, 2025, under Iowa Administrative Code 129-8.4(8B). It is an enterprise interim policy. Counties may copy it. They do not have to. Horning’s project is the local version of a rule Des Moines already posted.

STATE BANS ON GENERATIVE AI

• Free tools: ChatGPT-style products are barred for supported entities unless the Department of Management gives prior written approval.
• Personal accounts: A worker’s own AI login cannot be used for state work.
• Sensitive files: Internal communications and protected data may not be submitted into an AI system, used to train one, or run through tools such as automated meeting notetakers, without written DOM authorization.
• Blind trust: AI output cannot be used verbatim, treated as the only source, or used as the sole basis for a final business decision. A person has to check it.
• Code comments: If AI writes a stretch of software, that stretch must be walled off with comments at both ends, and it cannot carry intellectual-property rights.

The policy also requires human fallback when a chatbot faces the public, so a resident can leave the bot and reach a person. Training curricula have to be approved by the Department of Management before agencies roll them out. Discrimination through AI is barred under Iowa Code Chapter 216. Impersonation and privacy invasions are listed as prohibited uses alongside fake or misleading content.

Johnson County is late relative to that calendar, and early relative to the courts. Its staff may soon have to report each use, while licensed Copilot already sits in the Microsoft accounts many of them have, and while new Google and Microsoft halls keep drawing Iowa power. The file Horning wants is a log of the paste. The model on the other end of that paste was, in a literal sense, grown here.