What ChatGPT is and how organizations use it
ChatGPT is OpenAI's conversational AI product. It is available as consumer plans for individuals, as business and enterprise workspaces administered by an organization, and indirectly through the OpenAI API, which your own software or vendors' software may call.
Typical business uses include drafting and editing documents, summarizing long files, analyzing spreadsheets, writing and reviewing code, research, and customer-communication drafting. Each of these can involve internal or regulated information, which is why account type and configuration matter.
Verify current terms
Vendor plans, features, and contractual terms change often. Treat the descriptions on this page as a starting point and confirm the current terms, admin settings, and data-handling commitments for your specific plan directly with the vendor before relying on them.
What ChatGPT can access
A plain chat session only sees what a user types or uploads. Modern ChatGPT is considerably more capable than that, and each capability widens what the tool can reach:
- Uploaded files — documents, spreadsheets, images, and code that users attach. Uploaded content is processed by the vendor and may be retained according to the account's retention settings.
- Connectors — integrations that let ChatGPT search or read from services such as cloud drives, email, calendars, or code repositories through OAuth. A connector acts with the permissions of the user who authorized it.
- Custom GPTs and actions — configurable assistants that can call external APIs. An action can send data to, or retrieve data from, a third-party endpoint defined by whoever built the GPT.
- Agent and browsing modes — modes in which ChatGPT browses the web and takes multi-step actions on a user's behalf. Content it reads on the web is untrusted input.
- Memory and history — saved preferences and conversation history that persist across sessions, which means sensitive details shared once can be retained.
Key ChatGPT security risks
1. Consumer accounts used for work
The most common exposure is not a sophisticated attack; it is employees using personal or free accounts for work. The organization cannot see those accounts, cannot enforce retention or training settings, cannot require MFA, and cannot recover data when the employee leaves. Depending on the plan and the user's own data-control settings, consumer conversations may be used to improve models.
2. Sensitive data in prompts and uploads
Patient information, privileged legal matters, customer records, financial data, and source code routinely end up in prompts because they are exactly the material people want help with. Once submitted, that data is governed by the vendor's terms for that account, not your internal policies.
3. Connectors and OAuth scope
When a user connects a drive or mailbox, ChatGPT can read what that user can read. Broad OAuth grants often persist long after the original purpose, and users rarely review them. From a security perspective, a connector is a new identity with delegated access to company data.
4. Prompt injection through web content, files, and actions
When ChatGPT reads web pages, shared documents, or API responses, hidden instructions in that content can attempt to redirect the model — for example, to summarize a document and include data from another source in a link. This is indirect prompt injection, and the risk grows when the same session also has access to sensitive data or can take actions.
5. Unreviewed outbound communication
Drafts produced by ChatGPT are usually reviewed by a person. Agentic modes and actions that can send messages, submit forms, or post content change that assumption and should be governed like any other system that can speak for your organization.
Is ChatGPT HIPAA compliant?
No AI tool is "HIPAA compliant" on its own. HIPAA obligations attach to how a covered entity or business associate uses a service: whether a Business Associate Agreement (BAA) is in place that covers the specific product and plan, how the service is configured (retention, sharing, access controls, audit logging), and whether workforce use stays within what the BAA and your policies permit.
For ChatGPT specifically, the practical questions are: Does OpenAI offer a BAA for the exact product and plan you use? Is PHI limited to accounts covered by that BAA? Are consumer accounts prohibited for PHI and technically discouraged? Are retention and sharing settings configured to match your policies? If you cannot answer yes to each, PHI should not be entered.
FlashTower flags vendor-hosted AI systems with access to PHI and no recorded BAA as a Critical finding (FT-DAT-010), and flags any use of consumer accounts with highly sensitive data as Critical (FT-DAT-011). See our guide to HIPAA and generative AI.
Questions every organization should answer
- Which ChatGPT account types are in use today — including personal accounts used for work?
- Is there an approved business or enterprise workspace, and is it connected to SSO with MFA enforced?
- Which connectors are enabled, who authorized them, and what scopes were granted?
- What are the workspace's retention settings, and are they documented?
- Is there contractual confirmation that business content is not used for model training?
- Which custom GPTs with actions are in use, and where do those actions send data?
- Is agent or browsing mode permitted, and for which roles?
- What does your acceptable-use policy say employees may and may not enter?
Recommended controls
- Provide an approved business workspace so employees have a sanctioned option. Prohibition without an alternative drives usage to personal accounts.
- Connect it to SSO and enforce MFA, so access is removed automatically at offboarding.
- Review and restrict connectors. Enable only those with a documented business purpose; review OAuth grants quarterly.
- Configure retention to the shortest period that meets business needs and document the setting.
- Publish an acceptable-use policy that names prohibited data categories and the approved tool. See our AI acceptable-use policy guide.
- Govern custom GPTs and actions — require review before an action can send data to an external endpoint.
- Detect shadow use through OAuth grant reviews and expense reports. See shadow AI discovery.
- Record the tool in your AI inventory with owner, purpose, data accessed, and vendor terms.
How FlashTower assesses this
When you add ChatGPT to a FlashTower Scan, the Risk Engine evaluates how it is actually used in your organization — account type, data accessed, capabilities, autonomy, credentials, logging, and vendor terms — against a versioned, deterministic ruleset. These rules are the most relevant for ChatGPT. Each fires only when its stated condition is met. See how scoring works.
Identity
FT-IDN-001HighNo controls on unapproved (shadow) AI tools
Unapproved AI tools are neither blocked nor monitored, or this cannot be confirmed.
FT-AUT-010MediumTeam-wide use of consumer AI accounts
More than ten people use this AI system on a free or personal consumer plan.
Authentication
FT-AUT-001HighAI tools do not require multi-factor authentication
No AI tools require MFA, or MFA coverage cannot be confirmed.
Sensitive Data
FT-DAT-010CriticalAI system accesses health information without a BAA
The AI system accesses PHI, is vendor-hosted, and no Business Associate Agreement is in place.
FT-DAT-011CriticalHighly sensitive data in a consumer AI account
A free or personal consumer AI plan is used with health data, payment card data, privileged legal material, or credentials.
FT-DAT-012HighSensitive business data in a consumer AI account
A free or personal consumer AI plan is used with personal information, financial data, customer records, or source code.
Vendor Risk
FT-DAT-013MediumSensitive data processed without a data processing agreement
A vendor-hosted, non-consumer AI system accesses sensitive data and no DPA is recorded.
Model Risk
FT-DAT-014MediumNo confirmation vendor does not train on your data
A vendor-hosted, non-consumer AI system accesses sensitive data and there is no contractual confirmation the vendor will not train on it.
External Communications
FT-COM-001HighAI sends or publishes externally without review
The AI system can send email/messages or publish content without per-action human approval.
Third-Party Integrations
FT-3PI-001HighPrompt-injection exposure: web access combined with sensitive data or actions
The AI system can browse the web or call external URLs and also has sensitive data or high-impact capabilities.
Logging
FT-LOG-010MediumAI system with sensitive data is not logged
The AI system accesses sensitive data and its activity is not logged or logging is unknown.
Governance
FT-GOV-010HighUnapproved AI tool handles sensitive data
The AI system is not approved (employee-adopted) and accesses sensitive data.
Frequently asked questions
Is ChatGPT safe for businesses?
It can be used safely when employees use an organization-managed business or enterprise workspace with SSO, MFA, documented retention settings, reviewed connectors, and a clear acceptable-use policy. The highest risks come from personal accounts used for work and from sensitive data or connectors added without review.
Is ChatGPT HIPAA compliant?
No tool is HIPAA compliant by itself. What matters is whether a Business Associate Agreement covering your specific product and plan is in place, how the service is configured, and whether use stays within that agreement. Without a BAA that covers your use, do not enter PHI. Confirm BAA availability and scope directly with OpenAI.
Does OpenAI train on my company's ChatGPT data?
It depends on the account type and settings. Consumer accounts have user-level data controls; business offerings are governed by commercial terms. Confirm the current terms for your plan in writing and record them in your vendor register.
What is the biggest ChatGPT risk for most organizations?
Employees using personal accounts for work. The organization has no visibility, cannot enforce settings, and cannot recover data. Providing an approved alternative and detecting shadow use addresses most of it.
Should we block ChatGPT entirely?
Blocking without an approved alternative usually pushes use to personal devices and accounts where you have even less visibility. Most organizations are better served by sanctioning a managed workspace with clear rules.