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Practice Area 03

Data Privacy, Security & Responsible Data Practices

AI systems are data systems with higher stakes. Training pipelines, embeddings, retrieval stores, and telemetry all create privacy obligations. We advise on lawful data acquisition and use, AI-specific data protection impact assessments, biometric and sensitive-data rules, cross-border transfer mechanisms, and privacy-enhancing techniques — so your data strategy survives both product review and regulatory scrutiny.

Who this is for

Model trainers and fine-tuners, RAG and agent product teams, healthcare and fintech AI deployers, adtech and martech platforms, and any organization processing personal data at AI scale.

What you get

  • Training and evaluation data provenance reviews
  • AI-specific DPIAs and legitimate interest / consent analysis
  • Cross-border transfer and vendor data processing frameworks
  • Biometric, children's data, and sensitive-category compliance reviews
  • Synthetic data and de-identification strategy
  • Privacy-by-design reviews of product and model telemetry

Frequently asked questions

Do we need consent to train on user data?

It depends on the jurisdiction, the data, and your lawful basis. Some uses can rest on legitimate interests or contract with clear notice; others — biometrics, children's data, sensitive categories — face stricter consent or prohibition rules. We map your actual data flows against each regime rather than assuming one global basis works.

What is an AI-specific DPIA?

A data protection impact assessment tailored to model behavior: what data trains the system, what personal data can be inferred or regurgitated, how embeddings and logs are retained, who can access outputs, and what safeguards (minimization, access control, redaction, retention limits) reduce risk to an acceptable level.

Are embeddings personal data?

Often yes — or at least treatable as personal data — when they can be linked back to individuals or used to infer attributes about them. We design retention, access, and deletion policies for embedding stores with that possibility in mind.