What AI data types will require specific user notices?

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Specific User Notices May Be Required for Certain AI Data Types

Organisations in Singapore using personal data to train generative artificial intelligence (AI) models may be required to issue specific user notices. These notices would detail the AI model's functions, the personal data categories it utilises, and mechanisms for users to opt out or withdraw consent. The proposed guidelines aim to address concerns about potentially sensitive personal data being exposed or reconstructed by generative AI.
Personal Data Categories for AI Training

The types of personal data that could necessitate specific user notices encompass a broad spectrum, including names, email addresses, and transaction and location records. Additionally, video, voice, and other recordings fall under this category. For instance, a company developing a text-to-speech service would need to inform users that their voice recordings are used to train the AI model, explaining how this data aids in speech pattern recognition.
Scope and Sensitivity of Data

While the proposed guidelines mention "video, voice and other recordings" as examples, they do not provide an exhaustive list of all personal data types that would trigger the requirement for specific notices. The Personal Data Protection Commission (PDPC) is considering how Singapore's data protection framework should adapt to the increasing use of generative AI, with a particular focus on sensitive personal information that could be exposed or reconstructed.
Consent and Anonymisation Ambiguities

The proposed guidelines currently leave ambiguity regarding the explicit requirement for consent versus the sufficiency of an opt-out mechanism. Furthermore, it remains unclear whether these requirements would apply if personal data is anonymised before being used for AI training. The PDPC is currently undergoing a public consultation period to address these and other related questions concerning AI and data protection.

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What AI data types will require specific user notices?

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