Not necessarily. 

Under the GDPR, controllers are required to provide information relating to what personal data they process, and how that processing takes place. 

If the personal data the organization includes in AI prompts has been collected directly from individuals, those individuals should be provided with a copy of the organization’s privacy notice “at the

Data is typically needed to train and fine-tune modern artificial intelligence (AI) models. AI can use data—including personal information—to recognize patterns and predict results.

The GDPR permits controllers to process personal information if one (or more) of the following six lawful processing purposes applies:[1]

  1. Consent. A company may process personal information if it collects

Attorneys familiar with the European GDPR are acquainted with the bifurcation of the world into controllers and processors. For purposes of European data privacy, a “controller” refers to a company that either jointly or alone “determines the purposes and means” of how personal data will be processed.[1] A “processor” refers to a company (or

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

Data is typically needed to train and fine-tune modern artificial intelligence models. AI can use data – including personal information – in order to recognize patterns and predict results.

Companies that utilize personal information to train an AI may either be acting as a controller or a processor depending on the degree of discretion they

Data typically is needed to train and fine-tune modern artificial intelligence models. AI can use data – including personal information – in order to recognize patterns and predict results.

The EU’s General Data Protection Regulation (GDPR) permits controllers to process personal information if one (or more) of the following six lawful processing purposes applies:[1]

The following is part of Greenberg Traurig’s ongoing series analyzing cross-border data transfers in light of the new Standard Contractual Clauses approved by the European Commission in June 2021.

  • Background. Company A is an EEA controller that utilizes Company Z, a processor based in Country Q. Company Z does not have a legal presence