---
title: "Assess whether a client may use held personal information to train or fine-tune a model"
url: "https://ailawframework.com/practice/privacy-data-protection-and-cyber/assess-whether-a-client-may-use-held-personal-information-to-train-or-fi"
type: "task"
site: "AI Law Framework"
id: "A25-B1-3"
practice_area: "Privacy, Data Protection & Cyber"
tier: "red"
lawyer_review: "required"
jurisdictions: ["AU"]
last_reviewed: "2026-10-10"
---

# Assess whether a client may use held personal information to train or fine-tune a model

> Organise the original collection notices and purposes into a primary/secondary-purpose table for APP 6 analysis.

Canonical page: https://ailawframework.com/practice/privacy-data-protection-and-cyber/assess-whether-a-client-may-use-held-personal-information-to-train-or-fi  
Last reviewed: 2026-10-10

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [Privacy, Data Protection & Cyber](https://ailawframework.com/practice/privacy-data-protection-and-cyber.md) |
| Human involvement | Red: Lawyer writes; AI may check, clarify or collect data |
| How AI is used | Organise the original collection notices and purposes into a primary/secondary-purpose table for APP 6 analysis. |
| What the lawyer must review | Decide reasonable expectations and whether consent or opt-out is needed. |
| Written for / versions | Australia |

## Checking plan

**Lawyer-led judgement**

The lawyer makes the substantive assessment. Any permitted AI assistance remains supporting work with its own checks.

- What the AI does: Organise the original collection notices and purposes into a primary/secondary-purpose table for APP 6 analysis.
- What the lawyer does: Decide reasonable expectations and whether consent or opt-out is needed.
- Who reviews: Lawyer competent in the matter and the forum
- Basis: Planning guidance checked against the linked public sources on 10 October 2026. Confirm the current instrument before reliance.
- Why: The traffic light follows the consequence of an error and how much of the output the lawyer must check before it is used.
- Restriction: The lawyer leads the substantive decision. Any assistance stays inside the preparation described for this task.
- Written for: AU

## Checks the lawyer makes

1. Open the cited source and confirm it is the current instrument for this forum and this date.
2. Decide reasonable expectations and whether consent or opt-out is needed.
3. Compare the output with the source and the instructions, including material the output left out.
4. The responsible lawyer approves the exact output for its intended use, or sends it back.

## Notes

- Suggested working checks from the linked public sources. Read the source and confirm it applies to this forum and this date. The checks do not approve software or record that the work is done.

## Practical guide

Jurisdiction: Australia

**Deliverable**: Assess whether a client may use held personal information to train or fine-tune a model

**Inputs**

- OAIC: developing and training generative AI models
- The matter instructions and the documents the output will rely on.

**Example**: Stop before the result is filed, sent or relied on. Decide reasonable expectations and whether consent or opt-out is needed.

**Stop and escalate when**

- The cited source is not the instrument that applies to this forum or this date.
- The output states a fact, date, citation, figure or commitment that is not in the instructions or the source.
- The responsible lawyer has not approved the exact output for its intended use.

Checked 2026-10-10.

## Sources

- [OAIC: developing and training generative AI models](https://www.oaic.gov.au/privacy/privacy-guidance-for-organisations-and-government-agencies/guidance-on-privacy-and-developing-and-training-generative-ai-models) (checked 2026-10-10)

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*