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Add: EDPB Opinion 28/2024 on AI Models and GDPR#21

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2digitsleft:add-edpb-opinion-ai-models
May 18, 2026
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Add: EDPB Opinion 28/2024 on AI Models and GDPR#21
carloshvp merged 1 commit into
GenAI-Gurus:mainfrom
2digitsleft:add-edpb-opinion-ai-models

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@2digitsleft
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Adds EDPB Opinion 28/2024 on data protection aspects of AI models, and creates a new "Data Protection Authorities" subsection under "Standards & Frameworks" to house it.

What it is: Opinion 28/2024, adopted 17 December 2024 by the European Data Protection Board at the request of the Irish Data Protection Commission. Covers three core questions: (1) when an AI model trained on personal data can be considered anonymous, (2) when legitimate interest can serve as a legal basis for training or deploying AI models, and (3) consequences of training a model on unlawfully processed personal data. The most authoritative EU-wide position on the AI Act / GDPR intersection to date.

Why it belongs: The list's "Related EU Regulations" section already flags GDPR as intersecting with the AI Act (Article 10 data governance), but no actual DPA guidance is currently included anywhere. Opinion 28/2024 is the most-cited document at this intersection — referenced in virtually every major law-firm guide on the list. The AI Act's data governance obligations cannot be operationalised without DPA guidance, so the gap is real.

On the new subsection: I propose ### Data Protection Authorities under ## Standards & Frameworks (between ENISA Cybersecurity and OECD & International). DPA guidance is functionally a parallel governance layer to the standards bodies already in this section. If you'd prefer a different home — e.g., folding it into an existing subsection or placing it elsewhere entirely — happy to revise. One follow-up PR is planned for this subsection (the EDPB AI topic page as a living index), so two entries to start.

Checklist:

  • Directly relevant to EU AI Act compliance
  • Publicly accessible
  • Working link
  • Not already listed
  • Description under 100 characters
  • Hyphen separator
  • Table of contents updated

@carloshvp
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Thanks for the contribution @2digitsleft. This is a high-quality official source and the placement under Data Protection Authorities makes sense. CI is green, so I’m merging this now.

@carloshvp carloshvp merged commit 4bebef1 into GenAI-Gurus:main May 18, 2026
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2 participants