But most of those policies share a common blind spot: they stop at the front door. Think about who has access to your data, your systems, your processes, and your intellectual property on any given day. Not just your employees, everyone else too:
Do you know whether any of them are using AI? ...And if they are, do you know how they're using it?
If the honest answer is no, your AI governance program has a gap. A significant one.
Third parties using AI is not inherently a problem. AI-assisted work is increasingly normal, and in many cases it improves the quality and speed of the services your vendors provide.
The problem is operating without visibility. That consultant summarizing meeting notes may be pasting them into an AI tool. That developer writing code may be using an AI assistant that retains inputs. That vendor analyzing your documents may be running them through a model you've never reviewed and never approved. None of that is automatically a disaster, but all of it carries risk that your organization may be entirely unaware of. Not to mention, in the event something goes wrong, that distinction is unlikely to protect you.
When a data incident, compliance failure, or liability question lands in front of a regulator or in a courtroom, the question won't be nuanced. It won't be:
"Which company's AI made the mistake?"
It will be:
"Why didn't you know?"
This is a lesson the cybersecurity industry has already learned the hard way. Third-party risk is not a theoretical concern. It is one of the most consistent vectors for data breaches, compliance failures, and operational disruptions that organizations face today. The 2013 Target breach (still one of the most referenced examples in enterprise security) originated through a third-party HVAC vendor. The mechanism was different, but the principle is identical: your risk doesn't end where your organization ends. AI governance is arriving at the same conclusion, just a few years behind.
The next generation of vendor questionnaires and third-party risk assessments is already starting to evolve. For years, the core questions have centered on data security: How do you protect our data? What are your encryption standards? What is your incident response process?
Those questions aren't going away. But new ones are being added:
Organizations that haven't started asking these questions of their vendors are already operating with incomplete information. And organizations that can't answer these questions when their own clients ask will find themselves at a competitive and compliance disadvantage.
Closing this gap doesn't require a complete overhaul of your vendor management program overnight. But it does require intentional action:
1. Update your vendor contracts and agreements.
AI usage clauses are becoming standard practice in enterprise contracts. Your agreements should explicitly address whether vendors and contractors are permitted to use AI when handling your data, and under what conditions.
2. Add AI to your vendor risk questionnaires.
If you conduct third-party risk assessments — and you should — AI usage needs to be part of the evaluation. Ask vendors about their internal AI policies, approved tools, and data handling practices specific to AI platforms.
3. Extend your internal AI policy outward.
Your internal policy sets the standard for how your organization handles AI. That standard should be communicated clearly to anyone operating in your ecosystem, not assumed.
4. Don't wait for an incident to ask the question.
Organizations that build third-party AI governance proactively are far better positioned than those who scramble to understand their exposure after something goes wrong. By then, the data has already moved.
Building a strong internal AI policy is a necessary first step. But it is only a first step. The organizations that will navigate AI governance successfully over the next several years are the ones that recognize their risk perimeter extends well beyond their own employees and build their programs accordingly. Your consultants, vendors, contractors, and service providers are an extension of your operations. Their AI usage is your business problem. And the time to understand it is before anyone asks why you didn't.
At InfoPathways, we help organizations build AI governance frameworks that account for the full picture — including the third-party risk most programs are missing. Whether you're starting from scratch or looking to strengthen an existing policy, our team can help you identify gaps and build a strategy that actually reflects how your business operates. Contact InfoPathways today.