Assess use of held personal information to train or fine-tune a model

Key facts

Human involvement
RedLawyer-led
How AI is used
List the purpose stated in the existing notice, the training purpose the client describes, and the data categories. Write no opinion on whether the training use is permitted.
What the lawyer must review
Section 1798.100(c) requires collection to be reasonably necessary and proportionate to the purposes for which the information was collected or processed, as disclosed. A later use for model training is a different purpose unless the notice already covers it and the use stays inside that limit. You decide whether it does. Opinion 512 adds a separate duty: do not input information relating to a representation into a tool that will disclose it, unless the client has given informed consent or an exception applies. The tool writes none of that advice.
Written for / version
United States versionUS

Who does what

Who does what
RoleWhat they do
AssistanceSupporting preparation only. Consider narrowly defined preparation support after confirming the tool’s capability and permitted scope. The tool writes nothing into the document. Substantive advice, judgement and any restricted content remain with the responsible human.
LawyerPerform the substantive analysis and decisions. Independently check any permitted supporting work and approve the exact output for its intended use.

Checklist

  1. Confirm that the actual tool, feature and processing terms permit use of this information, including access, retention, training and disclosure conditions.
  2. Confirm the output against the client’s instructions and the complete relevant source material, including omissions or contradictions.
  3. Resolve exceptions and record the responsible lawyer’s approval of the exact output and intended use.

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