Google PaLM 2 AI model is under review by the Irish Data Protection Commission

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By David Brooks

As the national independent authority in Ireland, the Data Protection Commission (DPC) is responsible for protecting the personal data of individuals in the EU under the GDPR, the EU Law Enforcement Directive (LED) and the Irish ePrivacy Regulations.

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The DPC has opened an investigation into whether Google Ireland Limited complied with regulations in the development of its core AI model, Pathways Language Model 2 (PaLM 2), prior to cross-border processing of personal data of EU or EEA data subjects.

Before individual data is used, organizations must carry out a data protection impact assessment (DPIA) to ensure that fundamental rights and freedoms are taken into account and protected.

The GDPR states that a DPIA is necessary when a type of processing, in particular using new technologies and taking into account the nature, scope, context and purposes of the processing, is likely to result in a high risk to the rights and freedoms of natural persons leads.

A DPIA assessment demonstrates compliance and ensures that data controllers mitigate any data protection risks arising from a type of processing that involves high risk.

It aims, among other things, to ensure that processing is necessary and proportionate and that appropriate safeguards are in place given the risks.

This statutory investigation is part of the DPC’s broader efforts to regulate the processing of personal data in the development of AI models and systems.

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