Shadow AI Risk Management for CISOs in 2025
- Maya Rosenstein
- Jul 22
- 2 min read
Updated: Jul 24
By the Commugen Team
In today’s enterprise environment, AI is revolutionizing productivity, but much of this transformation happens outside the scope of security and compliance programs. Shadow AI, using generative AI tools without IT governance, introduces new, escalating cyber risks that demand attention from CISOs and risk leaders.
What is Shadow AI and Why Should CISOs Be Alarmed?
Shadow AI refers to the unsanctioned use of generative AI tools inside organizations, often through free trials, browser plugins, or embedded features in familiar platforms like Slack, Notion, or Excel.
These tools aren’t like traditional Shadow IT. They don’t just move or store data. They generate, interpret, and learn from it, introducing new risk and decision opacity layers that are almost impossible to track with standard tools.
Common examples include:
An HR recruiter using ChatGPT to write offer letters containing PII
A developer pasting source code into GitHub Copilot
A finance manager summarizing internal forecasts using Google Gemini
In each case, business-critical data is processed by third-party AI models with little to no visibility or retention policy.
Learn more about Managing Shadow AI Risk
Why Shadow AI is Spreading So Quickly
The “Invisible Adoption Curve”
Unlike approved tools that undergo procurement and onboarding, Shadow AI adoption begins with curiosity and often stays that way. Employees encounter free tools, embed them in everyday workflows, and share them with colleagues without raising alarms.
Why Shadow AI is Hard to Detect and Track:
No install trial: Used in-browser or embedded in trusted apps
No account control: Often accessed with personal logins
No logs or audits: Activity is encrypted and non-retainable
No DLP coverage: Prompts and outputs evade traditional filters
The result? GRC teams are flying blind.
“43% of IT leaders don’t know what AI tools their teams are using.”
- Salesforce, State of IT Report, 2024
“Samsung banned GenAI after confidential chip designs leaked via ChatGPT.”
- TechCrunch, 2023
Shadow AI vs. Shadow IT: What Makes it Riskier
Aspect | Shadow IT | Shadow AI | Why It Matters for CISOs |
Tool Type | Dropbox, Trello | ChatGPT, Copilot | Shadow AI creates content, not just stores it |
Detection | App inventory, firewall logs | Invisible to CASB/DLP | Requires behavior-based discovery |
Data Movement | File sharing | Data transformation | Prompts may leak PII, IP, regulated data |
Auditability | Some logs available | No retained history | No trail = no investigation post-incident |
Risk Category | Unauthorized access | AI bias, compliance breach | Requires new GRC frameworks |
Why GRC Teams Need to Act Before it’s Too Late
Shadow AI isn’t just an IT issue. It’s a full-spectrum GRC challenge:
Governance: Are AI tools covered in your policy? Do employees know what’s allowed?
Risk: What’s the business impact if unapproved AI use leaks trade secrets?
Compliance: Would you pass a GDPR, HIPAA, or ISO 42001 audit with zero AI usage documentation?
“68% of employees say they use GenAI without informing IT.”
- Cisco AI Readiness Index, 2023
Learn now how to deal with the threat with our full guide
on Shadow AI Risk Management