Tactical Guide
How to Discover Shadow AI
Practical methods to inventory unauthorized AI usage across your healthcare organization
The Discovery Challenge
Shadow AI is designed to be invisible. These are web-based SaaS tools accessed through personal accounts, personal credit cards, and consumer-grade services.
Traditional IT discovery methods (network monitoring, procurement records, endpoint management) won’t catch them. You need a different approach.
5 Discovery Methods
Combine multiple approaches to get a complete picture of shadow AI usage
Anonymous Staff Surveys
Easy
1-2 weeks
Send organization-wide surveys asking staff to self-report AI tool usage in a non-punitive, anonymous way
How to do it:
- Frame it as ‘helping us enable AI safely’ not ‘catching violations’
- Ask: What AI tools do you use? How often? For what tasks?
- Promise no individual consequences—focus on organizational learning
- Offer small incentive (gift card raffle) for completion
Effectiveness:
70-80% of usage discovered
Pros:
Fast, cheap, builds trust
Cons:
Self-reported data may be incomplete
Department Interviews
Medium
2-4 weeks
Conduct structured interviews with department leaders and frontline staff across clinical, administrative, and revenue cycle teams
How to do it:
- Interview 2-3 people from each major department
- Ask about productivity pain points and workarounds
- Listen for AI tool mentions (ChatGPT, Claude, Grammarly, transcription services)
- Document workflows where AI could be or is being used
Effectiveness:
60-70% of usage discovered
Pros:
Deep qualitative insights, relationship building
Cons:
Time-intensive, requires skilled interviewer
Network Traffic Analysis
Hard
1 week
Analyze DNS logs and firewall traffic to identify connections to known AI service domains
How to do it:
- Pull 30 days of DNS logs from your firewall/proxy
- Search for domains: openai.com, anthropic.com, claude.ai, gemini.google.com, etc.
- Look for unusual traffic spikes to AI service providers
- Correlate by department, time of day, user segments
Effectiveness:
40-50% of usage discovered
Pros:
Objective data, hard evidence
Cons:
Misses personal devices, VPNs, encrypted traffic
Browser Extension Audit
Medium
1 week
If you use endpoint management, audit installed browser extensions for AI writing assistants and productivity tools
How to do it:
- Export list of all Chrome/Edge extensions from endpoint management
- Flag AI-related extensions: Grammarly, Jasper, Copy.ai, Notion AI, etc.
- Check for ChatGPT desktop apps, Claude desktop apps
- Document which departments have highest adoption
Effectiveness:
30-40% of usage discovered
Pros:
Specific tool identification
Cons:
Only catches managed devices, misses web-only usage
Credit Card & Expense Review
Easy
1 week
Review corporate credit card statements and expense reports for AI tool subscriptions
How to do it:
- Pull 6 months of expense data
- Search for merchant names: OpenAI, Anthropic, Jasper, Copy.ai, etc.
- Look for recurring monthly charges ($20-50 range)
- Note: Most shadow AI is on personal cards, so this catches <10%
Effectiveness:
10-20% of usage discovered
Pros:
Easy to run, identifies paid subscriptions
Cons:
Misses majority of personal-account usage
Recommended Approach
Combine three methods for maximum coverage
Start with Anonymous Survey (Week 1)
Fastest way to get broad visibility. Most staff will self-report if framed correctly.
Run Network Traffic Analysis (Week 1-2)
Validates survey data and catches usage staff forgot to mention or didn’t realize counted as “AI”.
Follow Up with Department Interviews (Week 2-3)
Deep dive into high-risk or high-usage departments to understand workflows and PHI exposure.
Result: 80-90% coverage of shadow AI usage in 2-3 weeks, with both quantitative data and qualitative context.
What to Document
Not just a compliance issue. This is an existential risk for all organizations
Field 1
AI Tool Name
Example: ChatGPT, Claude, Gemini, Grammarly
Track this information for each discovered AI tool to build a complete shadow AI inventory.
Field 2
Department/Team
Example: Clinical Documentation, Revenue Cycle, Admin
Track this information for each discovered AI tool to build a complete shadow AI inventory.
Field 3
Number of Users
Example: Estimated count or percentage
Track this information for each discovered AI tool to build a complete shadow AI inventory.
Field 4
Use Case
Example: Summarizing notes, drafting appeals, patient education
Track this information for each discovered AI tool to build a complete shadow AI inventory.
Field 5
AI Tool Data Shared
Example: Patient names, diagnosis codes, treatment details
Track this information for each discovered AI tool to build a complete shadow AI inventory.
Field 6
PHI Exposure Level
Example: High, Medium, Low
Track this information for each discovered AI tool to build a complete shadow AI inventory.
Field 7
Account Type
Example: Personal account, free tier, paid subscription
Track this information for each discovered AI tool to build a complete shadow AI inventory.
Field 8
Frequency of Use
Example: Daily, weekly, occasional
Track this information for each discovered AI tool to build a complete shadow AI inventory.
What Happens After Discovery?
Discovery is just the first step—then you need to act on what you learned
Step 1
Prioritize Risk
Focus governance efforts where they matter most
Rank discovered tools by PHI exposure level, number of users, and business criticality. Focus governance efforts on highest-risk areas first.
Step 2
Communicate Findings
Make shadow AI visible to leadership
Present shadow AI inventory to leadership with risk assessment, compliance gaps, and recommended actions. Make the invisible visible.
Step 3
Build Governance Plan
Create a roadmap for safe AI enablement
Use discovery insights to create a roadmap: establish policies, deploy PHI protection, provide approved alternatives, and enable teams safely.
