GDPR & LLM Usage

Navigate European privacy law when using AI with personal data

Europe's Privacy Standard Affects Global Businesses

The General Data Protection Regulation (GDPR) applies to any organization that processes personal data of EU residents, regardless of where the organization is located. Fines can reach €20 million or 4% of global annual revenue, whichever is higher.

GDPR Fundamentals

Core Principles

1. Lawfulness, Fairness, Transparency

Process data legally, fairly, and with user awareness

2. Purpose Limitation

Collect data for specific purposes only

3. Data Minimization

Only collect what's necessary

4. Accuracy

Keep data accurate and up to date

5. Storage Limitation

Don't keep data longer than needed

6. Integrity & Confidentiality

Secure data appropriately

⚠️ Critical for LLM Usage

When you send personal data to an LLM, you are "processing" it under GDPR. You must have a legal basis, minimize data sent, ensure security, and comply with all GDPR requirements.

Data Processing Agreements (DPAs)

What is a DPA?

Similar to HIPAA's BAA, a Data Processing Agreement is required when you use a vendor (processor) to process personal data on your behalf (as the controller).

DPA Must Include:

  • • Subject matter and duration of processing
  • • Nature and purpose of processing
  • • Types of personal data and categories of data subjects
  • • Obligations and rights of the controller
  • • Processor obligations (security, confidentiality, sub-processors)
  • • Data subject rights (access, deletion, portability)
  • • Data breach notification procedures

Which LLM Vendors Offer GDPR-Compliant DPAs?

✓ Major Vendors with DPAs:

Google Cloud (Vertex AI) - DPA available, EU data residency options
AWS (Bedrock) - Standard DPA, EU regions available
Microsoft Azure (OpenAI Service) - DPA included, EU Data Boundary
Anthropic - DPA for enterprise customers
OpenAI - DPA for enterprise customers (Azure OpenAI recommended for EU)

Data Subject Rights

Right to Access

Individuals can request what data you have about them.

LLM Impact: Can you retrieve what personal data was sent to the LLM? Most vendors don't store request data long-term.

Right to Erasure ("Right to be Forgotten")

Individuals can request deletion of their data.

LLM Impact: Once data is used to train a model, it can't be "unlearned." Use zero-retention options.

Right to Data Portability

Right to receive data in a structured, machine-readable format.

LLM Impact: Ensure LLM outputs can be exported if they contain personal data.

Right to Object

Right to object to processing, especially for automated decision-making.

LLM Impact: If using LLMs for automated decisions (hiring, credit), must allow human review.

Cross-Border Data Transfers

⚠️ Major Compliance Challenge

Transferring EU personal data to countries outside the EU/EEA requires special safeguards. The US is NOT automatically considered "adequate" for GDPR purposes.

Transfer Mechanisms

1. EU Data Residency

Best Option: Keep data in EU regions only

Most cloud LLM providers offer EU-specific regions (e.g., eu-west1, europe-west3)

2. Standard Contractual Clauses (SCCs)

EU-approved contract terms for international transfers

Major vendors include SCCs in their DPAs

3. Adequacy Decisions

EU recognition that a country has adequate protection

Currently: EEA countries, UK, Switzerland, Japan, Canada (commercial), and a few others. US has limited framework (EU-US Data Privacy Framework)

GDPR Compliance Best Practices

DO: Establish Legal Basis

Ensure you have consent, contract, legal obligation, or legitimate interest

DO: Minimize Data Sent to LLMs

Only send the minimum personal data necessary for the task

DO: Use EU Data Centers

Configure LLM services to use EU regions for data processing and storage

DO: Update Privacy Policies

Disclose LLM usage in your privacy policy and data processing disclosures

DO: Conduct DPIAs

Data Protection Impact Assessments for high-risk processing activities

DO: Implement Data Subject Rights Processes

Have procedures to handle access, deletion, and portability requests

DON'T: Use Consumer LLM Services

ChatGPT Free and similar don't offer DPAs or GDPR guarantees

DON'T: Allow Training on Personal Data

Opt out of data being used for model improvement or training

Navigate GDPR Compliance with Confidence

We can help you implement GDPR-compliant AI workflows and select appropriate vendors