Can the data used to feed the model be linked to individuals?
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Can the data used to feed the model be linked to individuals?
Do you need to use unique identifiers in your training dataset? If personal data is not necessary for the model you would not really have a legal justification for using it.
If you answered Yes then you are at risk
If you are not sure, then you might be at risk too
Recommendations
- Unique identifiers might be included in the training set when you want to be able to link the results to individuals. Consider using pseudo-identifiers or other techniques that can help you protect personal data.
- Document the measures you are taking to protect the data. Consider if your measures are necessary and proportional.