When developing their models, AI providers use various data
sets. Sometimes these are provided by their clients, as in the case
of tailor-made chatbots, and sometimes the models are trained on
licensed or even publicly available data. In both situations, the
data sets almost always include personal data. Thus, AI developers
should carefully consider their obligations under the GDPR as well
as local privacy law, depending on what applies to them.
The million-dollar question
Privacy compliance, amongst other things, should be considered
as soon as training data is collected. Even if publicly available
data is used for training purposes (e.g. data published on
YouTube), it does not mean that such data can be freely used. This
is a standard misconception amongst AI developers. Training on data
sets that include personal data can take place only if the
developers have a lawful legal basis for processing such data.
Under the GDPR, this usually comes down to two things: