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 collection
Under the GDPR, does a company that uses personal information to train an AI need to allow individuals to request that their information be removed from the training data?
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
Under the GDPR, is an organization required to distribute its privacy notice to every individual whose information is used to train an AI?
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, what information should an organization that uses personal information to train an AI put in its privacy notice?
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…
Under the GDPR, do organizations that use personal information to train an AI need to minimize the amount of time training data is retained?
The term “data minimization” generally refers to two requirements within the GDPR: (1) a company should only collect 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 it needs…
FTC Proposes Changes to Health Breach Notification Rule
On May 18, 2023, the Federal Trade Commission (FTC) issued a proposed rule that would expand the existing Health Breach Notification Rule (HBNR) to cover health applications (apps) and other similar technologies. Given the rapid evolution of the health technology industry since the HBNR was issued in 2009, the FTC has expressed concern that the…
June 28 Webinar | Personal Information in the Franchise Relationship
Greenberg Traurig Shareholders Breton H. Permesly and Tyler J. Thompson will present the CLE webinar, “Personal Information in the Franchise Relationship,” on Wednesday, June 28 at 12:30 pm EDT. As privacy laws proliferate around the world while the value of customer personal information simultaneously increases, data has never been riskier or had…
Increased Global Regulatory Focus on Mobile Apps: What Companies Should Know
Data protection authorities worldwide, including France’s Commission Nationale de l’Informatique et des Libertés (CNIL), the California attorney general (CAG), and the U.S. Federal Trade Commission (FTC), recently have indicated their intention to increase privacy enforcement efforts against mobile apps. As the digital landscape continues to evolve, data protection and privacy concerns remain…
The Complete Handbook for Cross Border Transfers of Personal Information Utilizing the New European Standard Contractual Clauses
All contracts that used the traditional Standard Contractual Clauses must be updated and repapered by 27 December 2022. To help companies comply with the deadline, Greenberg Traurig’s Data Privacy & Cybersecurity Group has compiled a 90-page guide explaining how to apply the new Standard Contractual Clauses in over 40 different transfer scenarios – ranging from…
What is aggregated data?
The California Consumer Privacy Act and the California Privacy Rights Act specifically state that they do not restrict a business’s ability to collect, use, retain, sell, share, or disclose “aggregated consumer information.”[1] Aggregate consumer information is defined as “information that relates to a group or category of consumers, from which individual consumer identities have…