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Glad to see the Hamburg DPA going in a similar direction as what I was suggesting in the post below: tokens should not be viewed as personal data. Even at the level of the output, “the mere presence of plausible personal information in LLM output is not conclusive evidence that personal data has been memorized, […]
Does training of AI systems involve the processing of personal data, and is it permitted under the GDPR? These were the two fundamental questions that I have already looked into in two previous articles: On the date of that second article, the Cologne Higher Regional Court (the Oberlandesgericht Köln – the Cologne HRC) delivered a […]
This is an article that I wrote in the context of a Chatham House rules roundtable on questions to be tackled more extensively in the future regarding the interaction between AI systems & data protection. This particular one relates to AI agents and the notion of authority, notably as regards (i) the user’s perspective (subordination?), […]
AI-powered translation of the blurb of our AI-related talk on Tuesday 6 June in Antwerp: “Update on the AI Act and other regulations within Europe AI and Data Act: how to prepare for them? What impact does European legislation on data and AI have on the activities of Flemish companies and other organizations? And why […]
7 points after giving another in-depth presentation to global businesses on the path to NIS2 compliance (with a flavour of DORA and GDPR): (i) Having a broad enough team (“multidisciplinary” / “multi-stakeholder” / however you wish to call it) is not easy for many organisations, irrespective of their size (this is nothing new, but it […]
While everyone is shouting “it’s for realz now”*, what will the AIAct actually mean for most organisations? Awareness (“AI literacy”) obligations and obligations to ensure that people know (i) if they are interacting with an AI system or (ii) whether they are subject to an AI system – and safeguards to ensure that no high-risk […]
CJEU confirms in new judgment that if you use automated decision-making, you are not required to reveal your algorithm(s) to data subjects (para. 59), but you might be required to “inform the data subject of the extent to which a variation in the personal data taken into account would have led to a different result” […]
Yesterday, I had the pleasure of giving a 5h presentation on the latest case law on the GDPR and other data protection legislation at various levels (Belgium, other EU countries, the Court of Justice and the European Court of Human Rights) to Data Protection Officers from a broad range of organisations and companies. The past […]
AI-powered adtech = prohibited AI? Interesting perspective, though I have my doubts as to whether the typical adtech-related AI systems we encounter in Europe would be classified as “manipulative” (let alone harmful) under the EU AI Act – once we look at how things work in practice. After all, manipulation and influence are not the […]
Very important leak – current version, and potentially final, of the AIAct. Read Luca Bertuzzi’s explanations of the context carefully!
