Part 21: The Right Of Access To Large Language Models

If large language models contain or generate personal data, sooner or later data subjects will want to know about it. But how should access requests with regard to personal data contained in an LLM be answered in a compliant manner? In this part 21 of our AI blog series, we provide answers to this controversial question.

The issue of the right of access in connection with large language models discussed in this article is currently of particular interest for two reasons: First, various European data protection authorities currently have been confronted with complaints from data subjects on exactly this issue. Prominent among these is the complaint from Max Schrems' organisation, NOYB, in which a public figure (Max Schrems himself?) complains that his date of birth was incorrectly stated by ChatGPT and that OpenAI, as the operator of the service, refused to provide information regarding the content of their language models. But it is not the only such case (here is