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
| Role | What they do |
|---|---|
| Assistance | Supporting 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. |
| Lawyer | Perform the substantive analysis and decisions. Independently check any permitted supporting work and approve the exact output for its intended use. |
Checklist
- Confirm that the actual tool, feature and processing terms permit use of this information, including access, retention, training and disclosure conditions.
- Confirm the output against the client’s instructions and the complete relevant source material, including omissions or contradictions.
- Resolve exceptions and record the responsible lawyer’s approval of the exact output and intended use.