4 ms·

How can a model not be up to GDPR standards? Or are you talking about the services that provide those models? Genuinely interested.

chpatrick 3y ago
I would imagine that they hoovered up a lot of data from the internet to train it and don't know if it's private or not. They can't guarantee that the model won't print your home address if you ask it the right way.
- yreg 3y ago
  In that case it wouldn't matter where they make it available. GDPR protects EU citizens' data everywhere, including in US.
  - dekhn 3y ago
    I'm not really sure the law could work that way. I mean in the sense that they may have codified that but realistically I think a nation's laws ended their borders typically
    - yreg 3y ago
      GDPR applies globally. If you handle EU citizens data, you must conform to it. Of course you might not care, if you believe that the EU has no way of forcing you to pay a fine and if you are certain that you are never going to do any business in the EU. But in such case you might as well provide access to your models for EU IPs too. It makes no difference.
      - dekhn 3y ago
        how can a law apply globally? Ignore the idea that EU can fine you, under what basis do laws of a country apply to actions outside the country?
  - stavros 3y ago
    Yeah, but the EU can't do anything to you if you don't sell to the EU in the first place.
    - yreg 3y ago
      Then why block the access, if you are fine with violating EU law because they have no way to make you pay fines? The model access makes no difference.
      - stavros 3y ago
        To make sure they don't bother chasing you in the first place, because that would mean more work for you.
ben_w 3y ago
Any personal information which gets into those models makes them incompatible, by my (IANAL) reading. https://gdpr.eu/what-is-gdpr/ https://gdpr.eu/what-is-gdpr/ "Personal data" and "data processing" are (deliberately) drawn very broadly: """Personal data — Personal data is any information that relates to an individual who can be directly or indirectly identified. Names and email addresses are obviously personal data. Location information, ethnicity, gender, biometric data, religious beliefs, web cookies, and political opinions can also be personal data. Pseudonymous data can also fall under the definition if it’s relatively easy to ID someone from it. Data processing — Any action performed on data, whether automated or manual. The examples cited in the text include collecting, recording, organizing, structuring, storing, using, erasing… so basically anything.""" And, unlike the arguments about copyright in big AI models trained on the internet (is it 'fair use'? Don't ask me, IANAL!), the requirement for explicit and informed consent is something a general crawl will very clearly fail: """Purpose limitation — You must process data for the legitimate purposes specified explicitly to the data subject when you collected it.""" Furthermore, we don't know enough about how the models store knowledge/beliefs to be able to make any claim about accuracy: """Accuracy — You must keep personal data accurate and up to date.""" And as for confidentiality… for downloadable models, that's "by obscurity" only, due to the exact same research needed to resolve the previous point about accuracy, and even for secret models like GPT-4, nobody's really sure how to actually guarantee it won't leak info with the right prompt, and there's even some suggestion that this is actually impossible with current approaches because nothing is really deleted by RLHF: """Integrity and confidentiality — Processing must be done in such a way as to ensure appropriate security, integrity, and confidentiality (e.g. by using encryption)."""
- lagrange77 3y ago
  Ok, thanks. But does not providing - the personal data you can not have or process - to the EU market, make your position any better, legally?
  - junon 3y ago
    If it's trained on data covered under the GDPR then it means you're 1) a "data processor" of that information and 2) there's a risk of it reproducing that information in some form. In the case of #1, they probably do not have an agreement with the "data controller" in the case of scraping, which means #2 is a violation of GDPR. IANAL.
thibaut_barrere 3y ago
With people feeding more and more delicate questions (e.g. medical, mental health etc), which can lead to more trouble with what may be stored temporarily etc, GDPR definitely has an impact here (developers must take special care to be compliant etc).

chpatrick 3y ago

I would imagine that they hoovered up a lot of data from the internet to train it and don't know if it's private or not. They can't guarantee that the model won't print your home address if you ask it the right way.

yreg 3y ago
In that case it wouldn't matter where they make it available. GDPR protects EU citizens' data everywhere, including in US.
- dekhn 3y ago
  I'm not really sure the law could work that way. I mean in the sense that they may have codified that but realistically I think a nation's laws ended their borders typically
  - yreg 3y ago
    GDPR applies globally. If you handle EU citizens data, you must conform to it. Of course you might not care, if you believe that the EU has no way of forcing you to pay a fine and if you are certain that you are never going to do any business in the EU. But in such case you might as well provide access to your models for EU IPs too. It makes no difference.
    - dekhn 3y ago
      how can a law apply globally? Ignore the idea that EU can fine you, under what basis do laws of a country apply to actions outside the country?
- stavros 3y ago
  Yeah, but the EU can't do anything to you if you don't sell to the EU in the first place.
  - yreg 3y ago
    Then why block the access, if you are fine with violating EU law because they have no way to make you pay fines? The model access makes no difference.
    - stavros 3y ago
      To make sure they don't bother chasing you in the first place, because that would mean more work for you.

ben_w 3y ago

Any personal information which gets into those models makes them incompatible, by my (IANAL) reading. https://gdpr.eu/what-is-gdpr/ https://gdpr.eu/what-is-gdpr/ "Personal data" and "data processing" are (deliberately) drawn very broadly: """Personal data — Personal data is any information that relates to an individual who can be directly or indirectly identified. Names and email addresses are obviously personal data. Location information, ethnicity, gender, biometric data, religious beliefs, web cookies, and political opinions can also be personal data. Pseudonymous data can also fall under the definition if it’s relatively easy to ID someone from it. Data processing — Any action performed on data, whether automated or manual. The examples cited in the text include collecting, recording, organizing, structuring, storing, using, erasing… so basically anything.""" And, unlike the arguments about copyright in big AI models trained on the internet (is it 'fair use'? Don't ask me, IANAL!), the requirement for explicit and informed consent is something a general crawl will very clearly fail: """Purpose limitation — You must process data for the legitimate purposes specified explicitly to the data subject when you collected it.""" Furthermore, we don't know enough about how the models store knowledge/beliefs to be able to make any claim about accuracy: """Accuracy — You must keep personal data accurate and up to date.""" And as for confidentiality… for downloadable models, that's "by obscurity" only, due to the exact same research needed to resolve the previous point about accuracy, and even for secret models like GPT-4, nobody's really sure how to actually guarantee it won't leak info with the right prompt, and there's even some suggestion that this is actually impossible with current approaches because nothing is really deleted by RLHF: """Integrity and confidentiality — Processing must be done in such a way as to ensure appropriate security, integrity, and confidentiality (e.g. by using encryption)."""

lagrange77 3y ago
Ok, thanks. But does not providing - the personal data you can not have or process - to the EU market, make your position any better, legally?
- junon 3y ago
  If it's trained on data covered under the GDPR then it means you're 1) a "data processor" of that information and 2) there's a risk of it reproducing that information in some form. In the case of #1, they probably do not have an agreement with the "data controller" in the case of scraping, which means #2 is a violation of GDPR. IANAL.

thibaut_barrere 3y ago

With people feeding more and more delicate questions (e.g. medical, mental health etc), which can lead to more trouble with what may be stored temporarily etc, GDPR definitely has an impact here (developers must take special care to be compliant etc).