By NHI Mgmt Group Editorial TeamBased on Zluri: “8 Key Learnings about Shadow IT and Rethinking ITAM from Jeremy Boerger” (June 26, 2025)

TL;DR: Shadow IT, SaaS sprawl, and third-party data handling can outpace spreadsheet-based ITAM and leave organisations without clear ownership, contract oversight, or security accountability, according to Zluri's discussion with Jeremy Boerger. The governance problem is not visibility alone. It is the gap between knowing software exists and being able to control access, data flow, and offboarding.


At a glance

What this is: This is a discussion of why traditional ITAM falls short when SaaS purchases, Shadow IT, and third-party data handling move faster than manual governance.

Why it matters: It matters because IAM and security teams need visibility into software use, but also enforceable control over access, data responsibility, and offboarding once software is outside central procurement.


Context

Shadow IT becomes an identity and governance problem when software can be acquired outside central process, data can be handed to third parties, and no one can reliably answer who owns the access or the contract. In that environment, a spreadsheet can list assets but still fail to govern the identities, permissions, and data flows attached to them.

The article frames SaaS as a practical test of ITAM maturity, not just a catalogue problem. The important question is whether the organisation can control what happens after purchase, including account creation, data handling terms, and removal of access when the business relationship changes.


Key questions

Q: What breaks when shadow IT is only managed through inventory reviews?

A: Inventory reviews find tools, but they do not enforce behaviour. By the time a review is complete, data may already have been shared, copied, or retained outside approved systems. Effective shadow IT control needs continuous monitoring, policy enforcement, and a process for handling exceptions, not just periodic discovery.

Q: Why do browser extensions matter to identity and access governance?

A: Browser extensions matter because they are delegated software identities operating inside a user trust context. They can influence what the user sees, what they download, and what code reaches the endpoint. That makes them part of the access plane, especially when browser activity is tied to business systems and sensitive workflows.

Q: How should organisations govern shadow IT before it expands into operational risk?

A: Organisations should treat shadow IT as a governance problem, not just an isolated technology issue. The first priority is to map where unsanctioned tools are being used, then build business relationships that surface demand early. Security teams should bridge integration gaps quickly, align IT and business owners on approved alternatives, and create lightweight controls that reduce friction without blocking legitimate work.

Q: When does spreadsheet SaaS tracking stop being reliable?

A: It stops being reliable when the environment is large or dynamic enough that ownership, renewals, and licenses change faster than people can update the file. At that point, the spreadsheet becomes a lagging record, not an operating control, and teams need discovery and workflow-based governance instead of manual maintenance.


Technical breakdown

Why spreadsheet-based ITAM breaks under SaaS sprawl

Traditional ITAM assumes assets are comparatively stable, centrally procured, and easy to reconcile against a fixed record. SaaS breaks that model because business users can subscribe directly, expense the cost, and create live dependencies before IT has a complete view. The result is not just poor inventory hygiene. It is an identity and governance gap where the organisation may know a tool exists but not who can access it, what data it stores, or how quickly it can be offboarded.

Practical implication: move from passive inventory lists to governance processes that can track ownership, access, and lifecycle state for each SaaS service.

Third-party data handling creates accountability gaps

When data moves into a SaaS platform, the control problem extends beyond the app itself to the contractual and operational obligations surrounding it. The article highlights a common failure mode: organisations assume the vendor’s security posture transfers responsibility, even though the data owner still carries governance, regulatory, and business risk. That means SaaS governance is not only about access control. It is also about data location, backup handling, breach responsibility, and whether offboarding can actually remove exposure.

Practical implication: tie SaaS approval to data-handling terms, breach responsibility, and offboarding requirements, not just feature evaluation.

Shadow IT changes the control boundary for identity governance

Shadow IT alters the trust boundary because the organisation no longer controls the full procurement-to-offboarding path. A user can introduce a service, connect company data, and create an unmanaged access pathway without the normal review gates that ITAM and IAM depend on. In that model, lifecycle governance matters as much as discovery: the issue is not merely whether the software is known, but whether identities, entitlements, and third-party access can be revoked when business need ends.

Practical implication: connect SaaS discovery to identity lifecycle processes so unapproved services can be contained before they become unmanaged access paths.


NHI Mgmt Group analysis

Shadow IT turns ITAM into an identity governance problem. Once employees can subscribe to SaaS directly, the control question stops being what software exists and becomes who can bind organisational data and access to it. That is why software discovery alone is incomplete. Practitioners need to treat SaaS intake, owner assignment, and offboarding as part of the identity programme, not as a separate procurement clean-up exercise.

Contract language is part of the security control plane. The article makes clear that responsibility for data does not disappear when the data is outsourced. That means governance teams need to read SaaS agreements as operational control documents, because backup location, breach responsibility, and data handling terms determine where risk actually sits. The implication is that vendor review without lifecycle accountability leaves a false sense of control.

Spreadsheets do not scale into governable lifecycle state. A list of tools can help with visibility, but it cannot reliably enforce ownership, revocation, or third-party access closure. The key concept here is SaaS governance drift: the distance between knowing an application exists and being able to control its identity and data posture. Practitioners should recognise that drift as a structural limit, not an operational inconvenience.

ITAM, IAM, and security now intersect at the SaaS boundary. The article shows that SaaS decisions affect cost, access, data handling, and accountability at the same time. That makes this a cross-domain governance issue rather than a pure asset-management exercise. Organisations that separate procurement, ITAM, and IAM reporting will miss the point of control failure and should align them around lifecycle ownership.

The market has moved beyond static asset tracking. SaaS adoption has changed the unit of governance from a purchased licence to a living service relationship with access, data, and offboarding implications. That shift validates a broader identity lifecycle model for SaaS, where control must follow the service after purchase and not stop at inventory entry. The practitioner takeaway is to govern the relationship, not just the record.

What this signals

SaaS governance drift: the gap between inventory and control becomes the practical failure mode when employees can procure tools outside central review. Organisations should watch for services that have an owner on paper but no enforceable access lifecycle or data-handling oversight.

Spreadsheet tracking can still support discovery, but it cannot close the governance loop. The programme question is whether ownership, contract terms, and offboarding are all bound to the same record so that shadow IT does not become permanent access debt.


For practitioners

  • Map shadow SaaS to named business owners Create an accountable owner for every discovered SaaS application, including tools acquired outside procurement, so no service sits in an undefined governance state.
  • Review third-party data terms before approval Require a security and legal check for where customer, employee, or operational data is stored, backed up, and subject to breach responsibility before a SaaS service is sanctioned.
  • Tie SaaS discovery to offboarding When a service is retired or no longer sanctioned, verify that accounts, integrations, and data-sharing links are removed as part of the closure process.
  • Replace spreadsheet-only tracking with governed workflows Use a system that can record ownership, contract status, access scope, and lifecycle state instead of relying on static inventory lists that age as soon as users self-provision new tools.

Key takeaways

  • Shadow IT and SaaS sprawl expose a structural limit in ITAM because visibility without ownership and offboarding does not create control.
  • The article shows that data responsibility remains with the organisation even when software and storage move to a third party.
  • The practical response is to connect SaaS discovery, contract review, and identity lifecycle controls so unapproved services do not become unmanaged access paths.

Standards & Framework Alignment

This section maps relevant standards and security frameworks to the operational risks and controls described in this guidance.

OWASP Non-Human Identity Top 10 addresses the attack and risk surface, while NIST CSF 2.0 and CIS Controls v8 set the governance and control requirements practitioners need to meet.

FrameworkControl / ReferenceRelevance
NIST CSF 2.0GV.OC-01 — Organisational ContextThe article is about governance boundaries and ownership across SaaS use.
PR.AA-05 — Access Permissions, Entitlements and AuthorizationsShadow IT becomes risky when access and entitlement control are not tied to the service lifecycle.
Recommendation — Map SaaS ownership and accountability into governance processes before services escape central control. Bind SaaS access rights to an approval and revocation process that follows the service lifecycle.
OWASP Non-Human Identity Top 10NHI-01 — Improper OffboardingThe article repeatedly points to failure to remove access and close out services cleanly.
Recommendation — Track every SaaS service through offboarding so accounts and integrations are removed when use ends.
CIS Controls v8CIS-5 — Account ManagementUnmanaged SaaS accounts and duplicated subscriptions are a core control issue here.
Recommendation — Audit SaaS account creation and removal to keep shadow services from accumulating unmanaged identities.

Key terms

  • Shadow IT: Shadow IT is the use of applications or services outside formal enterprise approval or visibility. In SaaS environments, it often includes department-purchased tools and unsanctioned integrations that create hidden identity, data, and access paths the security team cannot readily govern.
  • SaaS Lifecycle Governance: SaaS lifecycle governance is the set of controls that manage applications from onboarding through access assignment, renewal, and decommissioning. It matters because the security value of SaaS management depends on whether the organisation can prove ownership, revoke access, and retire unused tools on demand.
  • It Asset Management: IT asset management is the discipline of tracking technology assets across their useful life so they can be procured, deployed, maintained, renewed, and retired with accountability. In security programmes, it becomes valuable when lifecycle records are tied to ownership, entitlement, and revocation decisions.
  • Lifecycle Ownership: Lifecycle ownership is the assignment of responsibility for creating, changing, reviewing, and retiring an identity or its access. For customer and non-human identities, weak lifecycle ownership usually shows up as orphaned access, inconsistent policy enforcement, and unclear accountability during change.

Deepen your knowledge

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NHIMG Editorial Note
Published by the NHIMG editorial team on June 11, 2026.
Updated on October 8, 2026.
NHI Mgmt Group, the independent authority on Non-Human Identity, IAM, and Agentic AI security. nhimg.org