A privacy officer at an accountancy firm is sent the AI register to review. ChatGPT is not in it, "because we never bought it". Copilot is, as a single row. A few questions later, it turns out that three kinds of ChatGPT and two kinds of Copilot are in use, and almost nothing has been recorded about any of them.
The answer to the question in the title is yes; the reasoning takes a little longer. An AI register describes what is used, not what was purchased. And for these two tools, "ChatGPT" or "Copilot" is not a row but an umbrella term for three or four situations that differ on the very fields a register records.
Why does a tool you never bought belong in the register?
Because the risk starts with use, not with the invoice. A tool nobody pays for but twenty people open processes the same data as a tool with a contract. The difference is that nobody has looked at the first one.
The register is where that assessment is recorded. Without a row there is no owner, no decision and nothing to show employees when they open the tool. That is why a register has four statuses rather than two: a tool that has been spotted but not yet assessed goes in as "No decision yet". That is an honest status, not an approval, and it is better than leaving the tool out. How the statuses work is explained in our article on the four statuses for AI tools.
What exactly counts as AI use that employees start on their own, and why it almost always runs through a free account, is covered in our explainer on shadow AI. For this piece, one point is enough: when nothing has been bought, people usually come in through a free account, so the key question for each row is which account sits behind the tool.
Why are free and business separate rows?
Because they differ on exactly the fields a register exists to record. The same tool on screen, different terms underneath: the account type matters more than the tool.
| Variant | Account | Training on input | Data processing agreement | Reach and connections |
|---|---|---|---|---|
| ChatGPT Free, Plus, Pro | Personal, not managed by the organisation | Possible, unless the user turns it off | No, consumer terms | Whatever someone pastes or uploads, plus memory, shared links and apps the user connects themselves |
| ChatGPT Business, Enterprise, Edu | The organisation's, with an administrator | Excluded by default | Yes | Whatever someone pastes or uploads, plus apps and connectors the administrator allows |
| Consumer Copilot | Personal, no work account | No enterprise data protection | No | The open web and whatever someone pastes |
| Microsoft 365 Copilot | Work account, paid add-on | Not for the underlying models | Yes, under Microsoft's terms | Mail, files, calendar, Teams and SharePoint, with the user's permissions |
There is a third Copilot: Copilot Chat with a work account, which has enterprise data protection. Outside Outlook it works with the web and with whatever the user adds. Inside Outlook it can use email, calendar, meetings, chats and a bounded set of files, even without a licence (Microsoft Learn, Microsoft Copilot Chat Privacy and Protections, checked 25 October 2026). In the reach field its answer differs from both variants in the table, which is why it gets a row of its own, between the two. Our article on Copilot Chat without a licence sets out what it can do. The details of each variant are in our articles on how Microsoft Copilot inherits your access and ChatGPT and work data.
Read the table column by column and you can see why one row will not do. The free version gets a different decision from the business version, because the risk is different. The free row needs an alternative (the business version), the business row a condition (which data may and may not go in). And the review works differently: consumer terms change without the organisation receiving any notice.
Which fields differ for these two compared with other tools?
For most tools in a register, the vendor, purpose and owner account for most of the work. For ChatGPT and Copilot, the differences lie in four other fields.
Account. Who owns the sign-in? With a personal account, the chat history, the memory and every shared link belong to the employee, and all of it walks out of the door when they leave. The organisation has no say over any of it. Record in the row whether the account belongs to the organisation and, if not, how people can move to the business variant.
Training. With personal accounts it is a setting the user has to switch off; with business variants, input is excluded from training by default. Record which applies, and keep it separate from retention: "no training" says nothing about how long a prompt is kept. That distinction is explained in our article on what "no training on your data" really means.
Data processing agreement. If the tool processes personal data on behalf of the organisation, Article 28 GDPR requires a data processing agreement (DPA), and only the business variants come with one. On the free row the field is therefore empty, and that fact shapes the decision. When a DPA is needed is covered in our article on data processing agreements for AI tools.
Reach and connections. This field is missing from most registers, yet for Copilot it is the most important. ChatGPT sees what someone pastes, uploads or connects through an app. Microsoft 365 Copilot sees everything the user is allowed to open, including the folder that was shared with "everyone" three years ago. The risk then lies not in the tool but in the permission structure, and the register should point to where that is being tidied up.
What does this look like in the register?
Back to the accountancy firm. After an afternoon's work, the single Copilot row has become three, and the missing ChatGPT has become two rows.
Microsoft 365 Copilot is allowed for the forty licensed users, with the head of operations as owner and a reference to the project reviewing SharePoint permissions. Copilot Chat with a work account is allowed. Consumer Copilot is not allowed, with Copilot Chat as the alternative. ChatGPT Business, used by the advisory team, is set to limited use, with one condition: no client data. And free ChatGPT stays marked "No decision yet" until the advisory team's owner has decided whether Business becomes the standard option for everyone.
None of this is an incident. The register now describes what actually happens, and every row says who is responsible.
One limitation is worth mentioning. Observing use tells you which domain was opened, not which account: chatgpt.com is chatgpt.com. The account type shows up in licences and the admin console, and in what the organisation has agreed. In BeeSensible's catalogue, the consumer and business tiers of the same tool are separate entries, each with its own risk score, and the free tier points to the business tier as the safer alternative. The organisation decides which status each row gets, in the AI register; the extension reports only the domain of a tool that was opened, without a user ID. There is more on the AI tools page.
