Your teams already have an AI strategy.
They just designed it themselves, one unapproved browser tab at a time.
Across my own year-end reviews with customers in tech, financial services, and healthcare, the pattern is the same: on the slide, AI is “in pilot.” On the ground, shadow AI is everywhere—and it’s quickly becoming a board-level risk.
This piece is about that gap, why it matters, and why keeping sensitive work on the device (instead of spraying it across random clouds) needs to be part of your answer.
What we mean by “shadow AI”
Let’s keep this simple.
Shadow AI is the use of AI tools, models, or services by employees (or vendors) without formal approval, oversight, or integration into your governance and security controls. (Baker Donelson)
It’s the AI version of shadow IT: tools that sneak into critical workflows because they’re useful, not because they’re safe. (ISACA)
And it’s not hypothetical anymore:
- One recent study found 59% of employees admit to using unapproved AI tools at work; 75% of those share sensitive data (employee records, internal docs, proprietary code). (TechRadar)
- Senior executives are actually more likely than frontline workers to use shadow AI—93% in one survey—often assuming they understand the risk well enough to “manage it.” (TechRadar)
- IBM’s 2025 Cost of a Data Breach research shows 20% of organizations in their sample already suffered a breach involving shadow AI, adding roughly $670,000 on top of the average breach cost. (IT Pro)
If you’re thinking “we’re still in the planning phase with AI,” you’re probably not. You’re in the clean-up phase—you just haven’t looked under the couch yet.
What shadow AI actually looks like in your org
Shadow AI is not some exotic corner case. It’s painfully normal behavior from people trying to do their jobs faster.
In tech
- Engineering & DevOps – Log dumps, stack traces, and architectural snippets pasted into public chatbots to debug issues faster. That often includes infrastructure details and secrets that would never pass a security review if sent to a vendor.
- Product & UX – Roadmap drafts, customer feedback exports, and design specs dropped into “free” AI slide/summary tools to prep stakeholder updates.
- Customer support & success – Full ticket histories and CRM notes fed into AI reply generators that live outside your official stack and logging.
None of this feels malicious to the employee. They’re just trying to move. But collectively, it’s a slow-motion data exfiltration program you never signed up for.
In financial services
- Analysts & research – Portions of risk memos, models, and strategy docs pasted into generic AI tools to “clean up language” or “get a quick summary”—often including material non-public information.
- Front-office & relationship managers – Client calls recorded and processed by unvetted meeting-note apps that store audio and transcripts in third-party clouds far outside your vendor due diligence.
- Ops & compliance – KYC/AML documents and contract packets run through unapproved OCR + AI extraction tools hosted who-knows-where.
Meanwhile, IBM’s 2024 data shows the average financial-industry breach costs around $6.08M, roughly 22% higher than the global average. (IBM)
Layer shadow AI on top of that, and you’re adding vendors and data flows your risk team doesn’t even know to assess.
In healthcare
- Clinicians – Dictation into consumer-grade transcription or “AI scribe” apps that have no BAA, no clear data residency, and unclear reuse of PHI.
- Admin & rev cycle – Eligibility checks, pre-auth letters, and discharge summaries pasted into general-purpose chatbots to simplify patient-facing language.
- Research teams – “De-identified” datasets fed into external AI tools that haven’t been vetted for re-identification risk.
Healthcare is already the costliest vertical for breaches. In 2024, the average healthcare breach cost hovered around $9.7–9.8M per incident, and recent summaries still put healthcare at or near the top of the list. (Elliott Davis)
Now add HIPAA civil penalties that can run up to $2.1M per year per violation category, plus potential state AG actions and class actions. (The HIPAA Journal)
Feeding PHI into unapproved AI isn’t a minor policy violation. It’s potentially regulatory kindling.
Why this is a board-level risk, not just “IT’s problem”
From a board’s point of view, shadow AI lands in three buckets: financial, regulatory, and workforce integrity.
- Financial impact
Let’s start with the money.
- The global average cost of a breach sits around $4.4–4.9M per incident depending on the year and methodology. (IBM Newsroom)
- In the U.S. specifically, recent IBM data puts the average breach at about $10.22M, the highest in the world. (Baker Donelson)
- IBM’s 2025 analysis suggests that when shadow AI is involved, you can tag on hundreds of thousands of dollars in additional costs (roughly +$670K on average) from extra forensics, difficult containment, and more complex vendor risk chains. (IT Pro)
Those numbers are before you count:
- Civil penalties and regulatory settlements (HIPAA, SEC disclosure issues, state privacy laws). (The HIPAA Journal)
- Class action settlements and compensation for impacted individuals—multi-million dollar payouts are quickly becoming normal. (The Sun)
- Business disruption and churn, which IBM notes are now among the largest contributors to breach costs globally. (IBM Newsroom)
For tech, finserve, and healthcare, these are not “IT incidents.” They’re earnings events.
- Regulatory & audit exposure
Regulators don’t care whether the thing that leaked data was called a “chatbot,” a plug-in, or a browser extension. They care about:
- Who accessed what.
- Whether you had reasonable controls.
- Whether your real practices match your written policies.
Shadow AI creates policy drift: the more your people rely on unsanctioned tools, the further your actual operations drift from your stated governance. That gap is where regulators, auditors, and litigators go hunting.
- Workforce integrity
Shadow AI is also a people problem.
When your best people feel they need to break policy just to do their job efficiently, you end up with:
- A culture where “the real work happens off the books.”
- Managers quietly tolerating risky behavior because the sanctioned tools are too slow or too locked down.
- A widening trust gap between the workforce and the functions that are supposed to be enabling them (IT, risk, compliance).
That’s workforce integrity. And if you’re not addressing it, you’re training your people to optimize for speed over safeguards.
Why banning AI tools doesn’t work
A lot of organizations tried to solve this with simple rules: “No AI tools,” “No external chatbots,” “Blocked domains.”
The data says that doesn’t work:
- Average enterprises are now using dozens of generative AI tools—one report puts it around 67 per company, with roughly 90% unlicensed or unapproved. (Axios)
- Employees reach for shadow AI precisely because they don’t have sanctioned options that match their workflow. When the choice is “break policy and finish in 10 minutes” or “follow policy and finish in 2 hours,” most people will choose the former. (TechRadar)
You will not win this with firewalls alone. You have to give people safe ways to get the same benefits.
Which brings us to on-device AI.
On-device AI as a design pattern, not a product logo
When I talk about “on-device” or “local” AI here, I’m talking about:
Models running directly on the employee’s laptop or desktop, using the device’s CPU, GPU, and—where available—NPU, without shipping raw data off to a vendor’s cloud.
Done right, this gives you a way to shrink your AI attack surface without asking people to go back to manual work.
Cephable does a lot of work with our partners, especially Intel, to optimize for their GPU and NPU enabled machines from OEMs like HP, Lenovo and Dell. The chipset Intel provides is an investment, sometimes future-proofing, but in reality the future is here when you can offload workloads to the local chip and protect the business at the same time.
Why on-device matters for shadow AI
- Data stays on the device
Summaries, rewrites, translations, and quick-generation tasks happen on the endpoint. Sensitive inputs—PHI, MNPI, customer PII, internal financials—never need to leave the network or hit a third-party API. - You can finally align AI with your data classifications
Instead of a blanket “no external AI” rule, you can say: - “These data classes (PHI, cardholder data, MNPI) must use local AI only.”
- “These classes can use private cloud.”
- “These low-risk classes can use approved public services.”
- You’re planning for, not against, hardware refresh cycles
A practical on-device strategy doesn’t assume everyone already has an “AI PC.” It should: - Run acceptably on current CPUs/GPUs across your existing fleet.
- Accelerate when NPUs are present, so your AI experience naturally gets faster as you refresh devices.
- Avoid hard dependencies that mean “no AI for you” if the machine is more than 18 months old.
- You leverage the hardware you already paid for
In most enterprises, endpoint hardware is a sunk cost line item. Using local compute for AI shifts part of the workload away from metered cloud calls and into the machines your CFO already funded. - You keep a single security and governance perimeter
If work is happening on sanctioned endpoints under MDM, EDR, and logging, you at least know where to look during an incident. Shadow AI scatters that work across random SaaS vendors with unknown controls and opaque training practices.
On-device AI isn’t a silver bullet. You still need good governance. But it lets you design AI into your environment on your terms, instead of reverse-engineering whatever tools your employees happen to like this quarter.
Cloud AI and on-device AI: which work belongs where?
This isn’t a turf war between cloud and local. You need both. The trick is matching workload to risk.
Here’s a simple way to think about it:
Cloud AI (when egress risk is acceptable)
- Public-facing content, marketing copy, generic research.
- Non-sensitive code assistance and documentation.
- Use cases where the speed and scale of large hosted models create clear value.
Guardrails: strong vendor due diligence, explicit data processing terms, logging, and clear allowed data classes.
On-device AI (when data must not leave)
- Clinical documentation, care notes, and internal patient communications in healthcare.
- Trading strategies, internal risk reports, pricing models, and deal memos in finance.
- Proprietary source code, detailed architecture diagrams, internal product roadmaps in tech.
- Any workflow where an accidental copy-paste into a random chatbot would qualify as a potential breach.
Guardrails: run only on managed endpoints; tie into your identity, logging, and device compliance posture.
Hybrid
Some workflows—like meeting summarization, claims intake, or underwriting—will mix data classes. The long-term direction for many organizations is:
- Local AI as the first touch on sensitive data.
- Optional, governed promotion of outputs (not raw inputs) into cloud AI services for additional enrichment, once you’re confident the content is safe to share.
The cost of not addressing shadow AI
If you choose to look the other way—keep AI in the “innovation” bucket and ignore the shadow reality—you’re effectively betting on four things:
- No one will ever paste the wrong thing into the wrong tool.
We already know that’s not true; 75% of shadow-AI users admit they’ve shared sensitive data. (TechRadar) - If a breach happens, it’ll be cheap.
The trend line says otherwise: - Global averages around $4.4–4.9M per incident. (IBM Newsroom)
- U.S. breaches averaging $10.22M. (Baker Donelson)
- Healthcare breaches pushing $7–10M on average. (Elliott Davis)
- Regulators will treat AI-related leaks as “new and confusing.”
They won’t. HIPAA, GLBA, SOX, SEC disclosure rules, and state privacy laws already cover unauthorized disclosure and insufficient safeguards. AI doesn’t buy you leniency; it just adds complexity. (The HIPAA Journal) - Your people will keep trusting your policies.
The longer you leave shadow AI as the path of least resistance, the more you train your workforce to treat policy as optional. That’s hard to unwind.
When you add it up, the cost of inaction looks like:
- Multi-million-dollar breach response and recovery.
- Ongoing audit scrutiny and corrective action plans.
- Talent burnout and quiet cynicism (“We say we care about security, but everyone knows the real work happens elsewhere.”)
- Opportunity cost: time spent cleaning up ungoverned AI instead of deliberately compounding value from governed AI.
Where to start in the next 90 days
If you’re a senior leader in tech, finserve, or healthcare, here’s a pragmatic starting play:
- Inventory reality, not intentions
Use network logs, CASB tools, and simple surveys to map: - Which AI tools are actually in use.
- Which teams are using them.
- What kinds of data they’re touching.
- Classify your AI workloads by sensitivity
Don’t start with tools; start with work: - What are the core “digital chores” in your org—summarizing, rewriting, translating, documenting, drafting?
- For each, what’s the highest data classification it touches?
- Design a split: local-first vs cloud-eligible
Decide: - Which workloads must be local-only because of PHI, MNPI, or regulatory exposure.
- Which can use private cloud (behind your firewall or in tightly controlled environments).
- Which can use public cloud services with the right guardrails.
- Pilot on-device AI on existing laptops/desktops
Pick a few teams (for example: a clinical unit, a research pod, an analyst group, or a product team) and: - Run a local-only AI pilot focused on repetitive “digital chores.”
- Measure reductions in copy-paste into unapproved tools, time saved per task, and user satisfaction.
- Validate that the experience works on your current hardware mix (CPU/GPU), while taking advantage of NPUs where you have them.
- Update governance so people can do the right thing by default
- Make AI policies readable and concrete: “For X-type data, use Y-type AI in Z place.”
- Create a clear path for employees to request new AI capabilities without going rogue.
- Ensure risk, compliance, and security are part of the design—not the department that says “no” after the fact.
Closing: This isn’t about being anti-cloud; it’s about being pro-control
Cloud AI isn’t going away, and it shouldn’t. It will continue to be the right answer for plenty of workloads.
But if you don’t pair it with a deliberate on-device AI strategy on the hardware you already own, you’re leaving the door open for your workforce to solve their own problems with shadow AI—and to drag your sensitive data right along with them.
If your end-of-year reviews are surfacing the same concerns—shadow AI, data leakage, and nervous questions about regulatory exposure—it’s a good moment to revisit how you’re balancing cloud and local AI inside your walls.
I’m always happy to compare notes on what I’m seeing across tech, financial services, and healthcare. Whether that’s a conversation that starts on our website’s contact form or a LinkedIn message, the important thing is that it starts—before your “AI strategy” is defined by the next unapproved download.

