u/heartmocog

Been thinking about this a lot lately because it keeps coming up in IGA engagements. The access control problem with LLMs isn't really about the tool itself, it's that, employees can completely bypass your entire entitlement model just by copying data into a prompt. You spend months building out a least-privilege access model, role mining, proper JML controls, and then someone pastes a customer export into ChatGPT to summarise it. That's your SoD framework out the window, and there's basically no audit trail in your IGA tooling to catch it. What makes this worse is the detection lag. From what I've seen in practice, and the data backs this up, organisations are typically discovering shadow AI usage more than 400 days after it started. That's a substantial exposure window, especially with GDPR enforcement accelerating the way it has. We're now seeing over 443 breach notifications daily across Europe and regulators are increasingly expecting organisations to demonstrate full data visibility and control, not just policy documentation. The orgs doing this reasonably well are treating it as a data classification problem first. If your sensitivity labels are solid and you've got DLP rules that can detect ChatGPT OAuth, requests or flag certain data types before they leave your environment, you've got at least some visibility. RBAC limiting who can even access the enterprise ChatGPT tier helps too, but that only covers sanctioned use. Shadow use through personal accounts is the harder problem, and that's where roughly 68% of employees are, actually operating, many of them pasting sensitive data without any awareness that it bypasses your controls entirely. Worth noting that OpenAI now auto-deletes consumer ChatGPT conversations after 30 days, so the indefinite, retention concern that used to come up is less of the issue it once was. The real risk is still the exfiltration moment itself, not long-term storage. And recent vulnerabilities have reinforced that point, there was a silent data exfiltration exploit patched earlier, this year that reminded everyone AI tools shouldn't be assumed secure by default regardless of vendor assurances. The EU AI Act enforcement kicking in from August 2026 adds another layer here too. High-risk AI system classifications could mean penalties up to €35 million or 7% of global turnover, so organisations, that haven't started mapping their AI usage against that framework alongside GDPR are going to find themselves managing

Been sitting on this for a while after going through a few tool evaluations recently. Every vendor demo follows the same script. Continuous monitoring, automated evidence collection, audit-ready dashboards, risk scoring out of the box. Sounds great. Then you actually implement it and spend the first few months doing manual mapping, fixing integration gaps, and rewriting templated policies that don't reflect how your org actually operates. What gets me is the pitch is almost always framed around efficiency, cost savings, faster audits. And look, those things matter. But there's still a gap between that and whether your compliance program is actually reducing risk in any meaningful way. The industry conversation has started shifting toward business outcomes, tying GRC success to real risk indicators and not just audit, closure speed, but I'm not seeing that translate into how these tools are actually sold or implemented on the ground. I've seen orgs hit SOC 2 with a shiny unified platform and still have no real visibility into their access risk or control failures. Checked the box, got the cert, program's still pretty fragile underneath. The tooling looks mature. The fundamentals aren't there. And that's the thing. These platforms are facilitators, not a fix. The continuous monitoring and automated evidence collection are real capabilities, but they only move, the needle if the underlying control design and policy structure are solid to begin with. Most of the implementation pain I've seen comes from orgs buying the software before they've figured out what they're actually trying to govern. Curious if others are running into this. Is the disconnect the tool, the implementation approach, or is it that orgs are still treating GRC as a certification exercise rather than an actual risk program?