FROM SHADOW AI TO AN APPROVED CATALOG

Enterprise AI Governance (Shadow AI)

We detect Shadow AI usage; a corporate AI policy and approved tool catalog are published, and a model governance framework secures safe value from AI.

ISO 27001ISO 27701KVKKDORA
01 Current state Topology, traffic, and dependency visibility.
02 Target architecture Segmentation, capacity, and availability design.
03 Controlled cutover Change window, validation, and rollback plan.
04 Hypercare Monitoring, tuning, and operational handover.
POSITION

Where this service sits in the portfolio

Capability card infographic for Enterprise AI Governance (Shadow AI)
SERVICE SCOPE

What this service addresses

The critical topics this service addresses and the outcome we deliver in each.

Visible AI-usage inventory

contract-scoped

We detect shadow-AI usage through network-traffic analysis, CASB integration and surveys, and tie it to an inventory.

Governance-ready evidence file

evidence readiness

We organise policy, risk map and the approved-tool catalogue as evidence ready for regulatory audit and customer enquiry.

Measurable adoption and maturity

measured target

We measure maturity on the AI Maturity Model and tie adoption and quality impact to trackable targets.

Risk-classification and compliance ownership

published after approval

We apply and evidence the EU AI Act risk classification; for high-risk systems the final conformity decision is left to your organisation and legal counsel.

Delivery model

Delivery approach

How we phase the service across delivery, governance, and connected service pillars.

  1. We build the current AI-usage inventory and assess risks against the EU AI Act's four-tier classification.

  2. We establish ethical-AI principles and a governance committee and define the approved-tool evaluation and approval process.

  3. With role-based training and a living-document structure we bring the framework under control without banning AI and keep it ready for regulatory change.

Operating contexts

Example operating contexts

Illustrative surfaces where this service is commonly activated.

Unapproved AI usage

Controlling the risk of employees moving corporate data to third-party systems via unapproved AI tools.

AI investment visibility

Moving scattered AI usage to central visibility and ROI measurement.

Regulatory readiness

Building a governance framework that aligns with the EU AI Act and KVKK AI annexes.

DEPTH

Technical and compliance depth

This service's depth on sector-specific technical and compliance topics.

Risk-classification framework

We classify tools on the basis of the EU AI Act's four risk tiers and the NIST AI RMF and set controls accordingly.

Governance-committee structure

With a committee of IT, legal, business-unit and ethics representatives we manage new tool requests and policy updates.

Living tool catalogue

We keep approved tools visible with a portal filtered by category and risk level and update it as vulnerabilities arise.

What It Solves

Shadow AI — unauthorized and unmanaged use of AI tools by employees across the organization — creates data exposure, intellectual property leakage, and regulatory compliance failures that occur entirely outside traditional IT governance visibility. Employees using public AI tools may inadvertently submit confidential contracts, customer data, source code, and regulated personal information to external model training pipelines. Enterprise AI Governance establishes the policies, technical controls, and oversight structures necessary to capture the productivity benefits of AI while maintaining control over data, model outputs, and regulatory compliance.

Shadow AI discovery — identify all AI tools in use across the organization via network and endpoint telemetry
AI acceptable use policy and vendor risk assessment framework
Model governance framework: risk tiering, approval workflows, output audit requirements
AI Act compliance readiness assessment for EU AI Act obligations (2025 enforcement)

Key Benefits

Benefit

Identify an average of 15-30 unauthorized AI tools per organization in shadow AI discovery assessments

Benefit

Eliminate uncontrolled personal data exposure to external AI providers, addressing KVKK/GDPR processor obligations

Benefit

Establish AI governance maturity that satisfies emerging EU AI Act Article 9 risk management requirements

Discovery
CASB, DLP, and network flow analysis for AI service identification
Policy
AI acceptable use policy, model risk management framework, vendor assessment template
Standards
EU AI Act (2024/1689), NIST AI RMF 1.0, ISO 42001:2023
Controls
Data loss prevention (DLP) rules for AI service categories, API gateway enforcement

Scope

Enterprise AI Governance addresses three interconnected domains: discovery and inventory (knowing what AI is in use), governance framework (establishing the rules, approval processes, and risk assessments for AI deployment), and technical controls (enforcing policy through DLP, CASB, and API gateway enforcement). Our engagement begins with a shadow AI discovery assessment that provides an immediate, evidence-based view of the current AI risk landscape before governance structures are designed — ensuring the framework addresses real, observed behavior rather than theoretical risks.

AI tool inventory and risk classification (approved, conditionally approved, prohibited)
AI vendor due diligence template with data processing, model training, and retention assessment
Prompt injection and model abuse risk assessment for organization-deployed AI applications
AI literacy and responsible AI use training for all staff

Key Benefits

Benefit

Support audit and compliance readiness with evidence records instead of unsupported public outcome promises

Benefit

Turn the outcome into a measurable target with baseline, owner, and review cadence

Benefit

Enable rapid, confident approval of legitimate AI use cases reducing time-to-approval from weeks to days

Discovery
90-day shadow AI discovery using CASB (Microsoft Defender for Cloud Apps or Netskope)
Classification
4-tier AI risk classification (approved/conditional/restricted/prohibited)
Review Process
AI use case intake, risk assessment, DPIA trigger evaluation, approval workflow
Enforcement
DLP policy profiles for AI service categories, browser-level CASB controls

Deliverables

Enterprise AI Governance delivers an operational governance program: a shadow AI discovery report, an AI inventory with risk classifications, an AI acceptable use policy, a model governance framework, technical control configurations, and a staff awareness program. For organizations pursuing formal AI governance certification, we deliver an ISO 42001 implementation roadmap and pre-certification gap assessment. All deliverables are designed to remain current as the AI tool landscape evolves through a structured quarterly review process.

Shadow AI discovery report with identified tools, usage patterns, and risk ratings
AI governance framework documentation: policy, procedures, risk tiers, approval workflows
Technical control implementation: DLP profiles, CASB configuration, API gateway rules
AI Act compliance gap assessment and remediation roadmap

Key Benefits

Benefit

Make risk and response indicators visible through measured controls, rehearsed playbooks, and evidence review

Benefit

Satisfy EU AI Act Article 9 risk management documentation requirements for high-risk AI deployments

Benefit

Turn the outcome into a measurable target with baseline, owner, and review cadence

Discovery Report
Tool inventory, usage telemetry, data exposure incidents, risk heat map
Policy Package
AI AUP, model risk framework, vendor assessment template, incident response addendum
Technical
CASB policy profiles, DLP rule sets, API gateway filter configurations
Training
AI literacy (all staff), responsible AI (developers), governance (management)

Frequently Asked Questions

Is using public AI tools like ChatGPT a KVKK violation?

It depends entirely on what data is submitted. Submitting personal data of Turkish data subjects to a US-based AI provider constitutes an international personal data transfer under KVKK Article 9, requiring either explicit consent or KVKK Board approval. Most organizations submitting customer data, employee information, or contract content to public AI tools are doing so without adequate legal basis — a direct regulatory violation. Our governance program establishes the policies and controls to prevent this.

What does the EU AI Act require from companies not based in the EU?

The EU AI Act applies to any organization that deploys or places AI systems on the EU market, regardless of where the organization is headquartered. Turkish companies with EU customers, EU-facing AI applications, or EU data processing operations are subject to the Act's requirements — including mandatory risk assessments for high-risk AI systems and transparency obligations for certain AI-generated content. We provide EU AI Act applicability assessments and compliance roadmaps for non-EU headquartered organizations.

How do you prevent legitimate AI use while blocking risky AI use?

Our governance framework uses a tiered approval model rather than blanket blocking. Approved AI tools (Microsoft 365 Copilot, Azure OpenAI with enterprise data protection agreements) are permitted with standard acceptable use policies. Conditional tools require specific approvals based on data classification rules. Restricted tools are blocked only for sensitive data categories. Blanket blocking reduces productivity without eliminating risk — employees find workarounds on personal devices.

Does ISO 42001 certification exist and is it worth pursuing?

Yes. ISO 42001:2023 is the international standard for AI Management Systems (AIMS), published in December 2023. Certification is available through accredited certification bodies and is increasingly being required in public procurement and high-regulation sector contracts. It is the AI governance equivalent of ISO 27001 — providing external verification of your AI risk management practices. We offer ISO 42001 implementation as an advanced component of our Enterprise AI Governance program.

How do we keep the AI tool inventory current as new AI tools appear constantly?

We establish a quarterly AI inventory review process supported by continuous CASB telemetry. New AI tools detected by CASB are automatically staged for risk classification review within the agreed response window of first detection. The AI governance owner performs a structured assessment using our vendor risk template, and approved or rejected tools are added to the classified inventory. This process keeps the inventory current without requiring manual scanning.

What is the liability exposure if an employee misuses AI under a governance program versus without one?

Under GDPR and KVKK, organizations bear controller liability for personal data processed by their employees using any tool, sanctioned or not. A documented governance program demonstrates that the organization took reasonable technical and organizational measures — a critical defense in regulatory investigations. Organizations without governance programs face the full liability of uncontrolled AI use combined with the inability to demonstrate any remediation effort, which regulators treat as an aggravating factor in penalty determinations.

STARTING POINT

Where should the conversation begin?

This short form routes your request to the right support team. We clarify context first, then define the safe sharing method.

  1. We capture context
  2. We choose a safe channel
  3. We clarify the first direction

Privacy-aware first contact; safe sharing flow when needed; no sales pressure.

Main request topic