Share on LinkedInShare on LinkedIn

ARTICLE · 17 APRIL 2023

Italy's Privacy Regulator Takes Action Against ChatGPT

WilmerHale
WilmerHale
Contributor
WilmerHale

WilmerHale

WilmerHale's London office was established more than 40 years ago. With lawyers qualified in the...

View firm profile
Explore more from WilmerHale

On March 31, 2023, Italy's privacy regulator (the "Garante"), announced an immediate temporary limitation on the processing of data of individuals residing in Italy...

ItalyTechnology
Dr. Martin Braun
Dr. Martin Braun
Matthew F. Ferraro
Matthew F. Ferraro
Author LinkedIn connections

On March 31, 2023, Italy's privacy regulator (the "Garante"), announced an immediate temporary limitation on the processing of data of individuals residing in Italy by OpenAI's ChatGPT, the popular artificial intelligence (AI)-powered chatbot. The Garante expressed concerns that OpenAI has unlawfully processed people's data, lacks a system to prevent minors from accessing the technology, and, because of a computer bug, allowed some users to see titles from another active user's chat history, among other issues.

The Garante's order mentioned several areas of concern with ChatGPT, including allegations of the following: the lack of information provided to users whose data is collected by and processed through ChatGPT; the lack of an appropriate legal basis for the collection and processing of personal data for the purpose of training ChatGPT's underlying algorithms; the lack of an age verification protocol for ChatGPT users; and the inaccuracy of some of the data

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

The Rules Of Artificial Intelligence: From The “Primacy” Of The Ai Act To Multilevel Fragmentation

As artificial intelligence regulation proliferates globally, the question has shifted from whether to regulate AI to how best to govern it across multiple jurisdictions. Italy's implementation of the EU AI Act through Law No. 132 of 2025 reveals both the challenges of multilevel governance and the critical role legal professionals must play in balancing innovation with rights protection.
European UnionTechnology
ADVANT Nctm
ADVANT Nctm
Article

Digital Omnibus On AI: How The European Commission Intends To Change The Rules On AI

The European Commission's Digital Omnibus Package proposes significant amendments to the AI Act, introducing targeted simplification measures for high-risk AI systems, extending regulatory relief to small-to-medium companies, and clarifying the interaction between AI regulation and existing EU legislation. The European Parliament has already published proposed amendments, with final adoption expected by the end of 2026 and gradual implementation beginning in 2027.
European UnionTechnology
Global Advertising Lawyers Alliance (GALA)
Global Advertising Lawyers Alliance (GALA)
Article

PTAB/USPTO Update - September 2026

The USPTO has released its latest economic impact report on IP-intensive industries, announced a new community engagement office in North Carolina, and issued several administrative updates including relief for Japanese applicants affected by a severe earthquake. The Patent Trial and Appeal Board has also designated new precedential and informative decisions addressing obviousness-type double patenting and Markush groupings.
United StatesIntellectual Property
WilmerHale
WilmerHale
Article

The SEC’s Transfer Agent Modernization Proposal: Implications For Onchain Recordkeeping

The SEC has proposed a comprehensive overhaul of transfer agent regulations that would formally recognize distributed ledger technology and blockchain-based recordkeeping systems within the existing regulatory framework. This modernization effort imposes enhanced operational, safeguarding, and compliance obligations while establishing technology-neutral standards that could significantly impact tokenization initiatives and digital asset market infrastructure.
United StatesFinance and Banking
WilmerHale
WilmerHale
Article

Climate Disclosure Update: California Issues Updated Regulations And Guidance For GHG Emissions Reporting

California's Air Resources Board has released significant modifications to its greenhouse gas emissions reporting regulation, deferring the first reporting deadline to November 10, 2026, and clarifying key requirements for companies doing business in California with over $1 billion in annual revenue. The updates provide additional flexibility for 2026 reporting while enforcement of the Climate-Related Financial Risk Act remains paused pending federal litigation.
United StatesEnvironment
WilmerHale
WilmerHale
Article

US ITC Seeks Public Comment On Reviving Its Section 338 Reporting Role Following The President’s Use Of Section 338 Tariff Authority

The US International Trade Commission has opened a rare public comment period on how it should fulfill its data collection and reporting obligations under Section 338 of the Tariff Act of 1930, a long-dormant authority recently invoked by the Trump Administration to impose restrictions on Canadian imports. This presents a unique opportunity for companies and stakeholders to shape from the ground up how the Commission interprets discriminatory foreign trade practices, evaluates allegations, and reports findi
GlobalInternational Law
WilmerHale
WilmerHale
Article

Washington Attorney General Publishes First Data Privacy Report

Washington Attorney General Nick Brown released the state's first Data Privacy Report, examining how the modern data economy incentivizes personal information collection and retention. The report catalogs resulting harms and recommends that lawmakers strengthen privacy protections, enforcement, and public education while highlighting Washington's continued lack of a comprehensive consumer privacy statute despite inspiring other states' privacy laws.
United StatesPrivacy
WilmerHale
WilmerHale
Article

Sports And Gaming Law In The First Half Of 2026: Top Five Developments

The sports and gaming industries are evolving faster than existing legal frameworks can accommodate, creating unprecedented jurisdictional battles, regulatory shifts, and commercial opportunities. From the escalating fight over prediction markets between federal regulators and states to the emergence of responsible gaming as a standalone policy priority, the first half of 2026 has reshaped the legal landscape governing these sectors while raising fundamental questions about innovation, consumer protection
United StatesMedia, Telecoms, IT, Entertainment
WilmerHale
WilmerHale
Article

Data Centers In Dispute: Contract And Treaty Claims In The Global Build-Out

As investment in data center infrastructure accelerates globally, disputes are emerging from contractual and investment-related risks that commonly accompany large-scale infrastructure projects. This analysis examines the growing wave of contractual claims among owners, contractors, and subcontractors, as well as investment treaty claims that may arise when governmental actions impact overseas data center developments.
United StatesLitigation, Mediation & Arbitration
WilmerHale
WilmerHale
Article

FARA’s Future: DOJ Signals Regulatory Revisions And Heightened Enforcement Action

The US Department of Justice has signaled a potential expansion of enforcement under the Foreign Agents Registration Act (FARA) and Section 951, despite earlier indications of limited criminal enforcement. Recent regulatory developments, policy announcements, and high-profile prosecutions of US officials suggest a renewed focus on foreign agent disclosure requirements and potential criminal liability for undisclosed relationships with foreign governments.
United StatesGovernment, Public Sector
WilmerHale
WilmerHale
Article

Recent DOJ Settlements Highlight False Claims Act Scrutiny Of Medicare Advantage Providers

The U.S. Department of Justice has announced three major settlements totaling over $558 million against healthcare providers partnering with Medicare Advantage plans for allegedly submitting false diagnosis codes. These enforcement actions reveal DOJ's intensified scrutiny of risk-sharing payment arrangements between Medicare Advantage plans and healthcare providers, while demonstrating the significant benefits that self-disclosure and cooperation can provide to companies facing potential False Claims Act l
United StatesFood, Drugs, Healthcare, Life Sciences
WilmerHale
WilmerHale