Last updated: February 9, 2026
Disclaimer: This advisory is for educational purposes and is not legal advice.
You don’t “roll out” AI (artificial intelligence) anymore. It just shows up—like a new kind of spellcheck that can write, summarize, and answer questions.
And that’s the problem: most client-data leaks through AI (artificial intelligence) aren’t dramatic hacks. They’re normal people trying to move faster.
The 5-minute leak map (do this with a pen, not a committee)
Minute 1: Prompt boxes (copy/paste is the #1 leak)
If your staff can paste client info into a chat box, your firm has a leak path.
- “Rewrite this email to the client…”
- “Summarize these notes…”
- “Turn this into a template…”
Why it leaks: The moment text leaves your controlled system and enters a third-party service, it’s a disclosure—even if it’s not used for training.
Rule of thumb: If you wouldn’t forward it to a stranger, don’t paste it into AI (artificial intelligence).
Minute 2: File uploads (“summarize this document” is a data-export button)
Uploads are higher-risk than pasting because you often export more than you think (metadata, hidden content, attachments, embedded comments).
Fast mitigation: Ban file uploads into any AI (artificial intelligence) tool that isn’t explicitly approved and contract-covered.
Minute 3: Connected apps + plugins (your AI (artificial intelligence) gets hands)
This is the “it looked convenient” leak: connecting Email, Drive, CRM (customer relationship management), or chat tools.
Staff guidance: No connecting work accounts to AI (artificial intelligence) tools unless IT (information technology) approved it.
Minute 4: Built-in assistants in tools you already use (safe-ish isn’t safe)
Business controls can be safer than consumer defaults, but you still have to understand retention, access, and admin settings.
- OpenAI: How your data is used to improve model performance
- OpenAI: Enterprise privacy
- Microsoft: Enterprise data protection for Microsoft 365 Copilot (Microsoft 365 AI assistant)
- Google: Gemini in Google Workspace (Google Workspace AI assistant) data and privacy
Key point: “Not used for training” doesn’t automatically mean “no risk.” Training is only one slice of exposure.
Minute 5: Mobile + browser layer (the stealth leak)
- AI (artificial intelligence) browser extensions that can see what’s on the page
- Screenshotting client documents and asking AI (artificial intelligence) to extract/summarize
- Personal device + work email + consumer AI (artificial intelligence) apps
Fast mitigation: If you allow BYOD (bring your own device), you need MDM (mobile device management) and a clear “no client data into consumer AI (artificial intelligence)” rule.
The 4 ways client data leaks
- Direct disclosure: You paste or upload confidential content.
- Indirect disclosure: You “anonymize” but include enough detail to identify a client or matter.
- Embedded disclosure: Hidden doc content (tracked changes, comments, metadata).
- Retention/logging disclosure: It’s stored somewhere, for some period, by someone.
A simple policy staff will actually follow (5 rules)
- Never paste these into AI (artificial intelligence): names tied to matters, SSN (Social Security number), DOB (date of birth), tax IDs, bank data, PHI (protected health information), privileged/confidential facts.
- Use AI (artificial intelligence) only in approved environments: business accounts only; personal accounts are a no for client work.
- Redact safely: use placeholders like [CLIENT], [AMOUNT], [DATE]; remove rare identifying details.
- No connectors without approval: no Email/Drive/CRM (customer relationship management) connectors unless approved.
- Report fast if it happens: early reporting beats cover-ups.
Mini incident response (when it already happened)
- Stop the behavior (tool, account, what was shared).
- Document the facts (date/time, content category, potential impact).
- Assess scope (single prompt vs upload vs connector access).
- Contain (disable account/extension/connector; rotate credentials if needed).
- Decide next steps with counsel/compliance (notification, client comms, remediation).






