"The first administrative guidance to generative AI platform and Alerts regarding the use of generative AI services issued by PPC"

The first administrative guidance to generative AI platform and Alerts regarding the use of generative AI services issued by PPC

The Japanese Personal Information Protection Commission (“PPC”) has issued administrative guidance regarding the protection of personal information by generative AI platforms. On June 1, 2023, the guidance was issued to OpenAI, L.L.C. and openAI OpCo, LLC pursuant to Article 147 of the Personal Information Protection Act (Law No. 57 of 2003). The warning addresses two primary concerns.

First, the PPC requires that Open AI take necessary steps to ensure that it does not collect sensitive personal information for machine learning purposes without the consent of the affected individual. If such information is collected, Open AI must delete it as soon as possible, and at least before processing it into datasets for training purposes. Additionally, the guidance requires that the purpose of using personal information must be within purpose notified to the affected individual or made public.

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