An article by an IAPP contributor discusses the European Data Protection Board (EDPB) Opinion about the use of personal data for the development and deployment of AI models. The author argues that while the EDPB's Opinion primarily advised data protection authorities (DPAs) to consider the anonymity status of AI models on a case-by-case basis, it indirectly provides data protection and AI governance practitioners with insights concerning how to operationalise its recommendations in practice.
The article addresses several areas:
- Establish procedures to assess AI model anonymity and personal data identification risks
- Fine-tune the legitimate interest assessments (LIA) template
- Amend data subjects' rights handling procedures
- Updating privacy notices and transparency information
- Establish and implement a web scraping policy
- Amend data protection due diligence processes

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