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Analysis

Enterprise AI has a data-in-use problem

Most organisations still assess AI with a checklist written for cloud storage. It asks where the data lives and whether it is encrypted. Both are reasonable questions. Neither one describes what an AI system actually does.

25 August 2026 · A shorter version of this argument first appeared on LinkedIn →.

The two states everyone checks

Security teams have spent fifteen years getting good at two questions. Is the data encrypted at rest, sitting in storage? And is it encrypted in transit, moving between systems? Answer both and most cloud procurement is satisfied.

Those controls are mature, well understood and largely solved. They are also, for AI, insufficient — because neither of them describes the moment the work happens.

The third state

To answer a question about a contract, a model has to read the contract. To check a report against a policy, it has to process both. There is no version of useful AI that does not, at some point, hold your material in memory and compute over it.

That moment is a third state: data in use. The idea is not new — confidential computing has been circling it for years — but AI is the first mainstream workload where the third state is the entire point. Encryption at rest protects a file nobody is reading. Encryption in transit protects a file in motion. Neither protects a file being understood.

At rest

Sitting in storage, read by nobody.

✓ Encryption covers this

In transit

Moving between systems.

✓ Encryption covers this

In use

Being read, held in memory and computed over.

Where AI does the work

Two of these are well covered by controls most organisations already have. The third is the one AI cannot avoid — and the one a storage-era checklist never thinks to ask about.

The useful question is no longer where is our data stored? It is who processes it, where, under what contract, and what happens to it afterwards?

Four assumptions worth testing

Where AI procurement usually stops short

1. “Not used for training” is not “not processed”

This is the assurance most often quoted to us, and it is usually true — while answering a different question from the one asked. A commitment not to train on your data is a commitment about one downstream use. It says nothing about whether your material is read, cached, logged, retained for diagnostics, inspected for abuse, or held to satisfy an audit obligation.

All of those can be entirely legitimate, and several are requirements the vendor could not waive if it wanted to. The point is narrower: we do not train on your data and nobody else processes your data are different sentences, and only one of them is usually on offer.

2. Where data lives is not where it is processed

Residency commitments generally describe storage. Inference — the moment the model actually runs — can be governed separately, and sometimes is. A service can hold your files in your region and still compute over them somewhere else.

There is a live, published example of exactly this pattern — including a mainstream platform on which the behaviour is switched on by default for new tenants in some regions. We keep it dated and sourced alongside the comparison table rather than repeating it here, so there is one version to maintain: see the data-exposure comparison →

3. Removing names (PII) does not make it safe

De-identification is a genuinely useful control. For person-linked records it can be the difference between needing a private deployment and not needing one.

It has a hard limit: it removes what is personal, not what is valuable. A pricing model contains no personal information. Neither does a set of engineering drawings, an unreleased design, a source file or a tender response. Strip every name out of those and the commercially sensitive part is entirely intact, because the sensitivity was never in the identity.

So de-identification is a real lever for one class of material and no help at all for another. Knowing which class you are holding is the decision; the technique is the easy part.

4. Two products, one brand, different architectures

Product families share a name, a login and a bill. They do not necessarily share an architecture. Within one vendor’s ecosystem you can find services with different processing locations, different retention behaviour, different contractual terms and different administrative controls.

That is not deception. It is what happens when a portfolio grows by acquisition and iteration. But it does mean we are already on that platform is not an answer to where does this particular workload get processed? The unit of assessment is the service, not the supplier.

What this does not argue for

None of this is a case for putting everything behind a private deployment. Most organisations hold a mix, and the mix is the whole point:

The work is matching each job to the lightest arrangement its data actually allows. That requires knowing, per workload, what the material is and who touches it in the course of answering. Not per vendor. Per workload.

Which is also why the honest answer to is this safe? is usually another question: safe for what, holding what, processed by whom?

Where does your own material sit?

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