AI GDPR Compliance Policy
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Common Compliance Questions
Q: Does GDPR apply to AI models trained on public data?
Yes, if that public data contained EU residents' personal identifiable information (PII) and was not properly scrubbed.
Q: What is the 'right to explanation' under GDPR in AI?
Article 22 grants users the right to understand the logic behind automated decisions that significantly affect them.
Q: How do I handle a 'right to be forgotten' request if data is embedded in model weights?
It is technically difficult to delete data from trained weights; thus, you must prevent PII ingestion or use machine unlearning techniques.
Q: What role does a Data Protection Officer (DPO) play in AI compliance?
A DPO oversees AI data flows, ensures DPIA completion, and validates compliance with GDPR automated decision rules.
Q: Can we use user prompts for model improvement under GDPR?
Only if you have explicit, freely given consent, or anonymize the prompts completely before storage.
Q: What is a DPIA for AI systems, and when is it required?
A Data Protection Impact Assessment is legally required before deploying high-risk automated processing like AI profiling.
Q: How does GDPR treat third-party LLM API integrations?
The API provider is a Data Processor, requiring a signed Data Processing Agreement (DPA) to legally transfer user prompts.
Q: What are the penalties for non-compliant AI systems under GDPR?
Fines can reach up to €20 million or 4% of global annual turnover, whichever is higher, plus potential EU AI Act penalties.