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David Zetoony, Co-Chair of the firm's U.S. Data, Privacy and Cybersecurity Practice, focuses on helping businesses navigate data privacy and cyber security laws from a practical standpoint. David has helped hundreds of companies establish and maintain ongoing privacy and security programs, and he has defended corporate privacy and security practices in investigations initiated by the Federal Trade Commission, and other data privacy and security regulatory agencies around the world, as well as in class action litigation.

Companies across industries are considering whether, and how, to utilize artificial intelligence (AI). Once developed, an AI can be utilized in a variety of different ways.

Input data is data added to an artificial intelligence (AI) to explain a problem, situation, or request. Input data may be cleaned, labeled, and organized, or it may be

The term “data minimization” generally refers to two requirements within the GDPR: (1) a company should only collect and process personal data that is “necessary” in relation to its purpose, and (2) a company should keep data for “no longer than is necessary for [that] purpose[].”[1] Put differently, a company should only collect what

Data is typically added to an AI to explain a problem, situation, or request (“input data”). Some popular AI models refer to input data by the term “prompt” as the user is prompting the AI to initiate an action, or to create additional information. Prompts can take different forms such as text prompts or image

Data is typically added to an AI to explain a problem, situation, or request (“input data”). Some popular AI models refer to input data by the term “prompt” as the user is prompting the AI to initiate an action, or to create additional information. Prompts can take different forms such as text prompts or image

Data is typically added to an AI to explain a problem, situation, or request (“input data”). Some AI providers, particularly those that provide natural language or large language models, refer to “prompts” as a subset of input data that describes the instructions that have been provided to the AI model (i.e., “please summarize the following

Data is typically added to an AI to explain a problem, situation, or request (“input data”). Some AI providers, particularly those that provide natural language or large language models, refer to “prompts” as a subset of input data that describes the instructions that have been provided to the AI model (i.e., “please summarize the following

The GDPR allows individuals to request that their information be deleted in the following situations:[1]

  • Companies must delete data upon request if the data was processed based solely on consent. The GDPR recognizes that companies may process data based on six alternate lawful grounds.[2] One of these is where a person has given

The right of correction (sometimes called the “right of rectification”) refers to a person’s ability to request that a company fix any inaccuracies in the personal data it holds about them.[1] Correction is sometimes referred to as an absolute right in the context of the GDPR, because unlike some other rights conferred by the

Under the GDPR controllers are required to provide information relating to what personal information they process, and how that processing takes place.[1] Data is typically needed to train and fine-tune modern artificial intelligence models. If that training data contains personal information, an organization is required to include a description of that processing in its

Under the GDPR, controllers are required to provide individuals with information relating to what personal information is processed, and how that processing takes place.[1] Some supervisory authorities have specifically taken the position that companies which use personal information to train an artificial intelligence (AI) must draft and publish a privacy notice that provides “data