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Under the GDPR, do organizations need to provide correction rights with regard to training data?

By David A. Zetoony on July 17, 2023
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The right of correction (sometimes called the “right of rectification”) refers to a person’s ability to request that a company fix any inaccuracies in the personal data it holds about them.[1] Correction is sometimes referred to as an absolute right in the context of the GDPR, because unlike some other rights conferred by the regulation which are dependent upon the lawful purpose of processing (e.g., the right of erasure), the right of correction applies regardless of the lawful purpose relied upon by an organization.

Data is typically needed to train and fine-tune modern artificial intelligence models. If personal information used to train or fine-tune an artificial intelligence is stored within an environment for continued use by the AI (i.e., continued pattern recognition), the organization may need to offer individuals the ability to have any inaccuracies in that information corrected.

In the context of training an AI, some supervisory authorities have taken the position that companies which use publicly sourced data (e.g., data scraped from the internet) should create an online tool that individuals can use to “request and obtain rectification of any personal data relating to them.”[2]


[1] GDPR, Article 16.

[2] Garante Per La Protezione Dei Dati Personali, Provision of April 11, 2023[9874702] (English translation). 

  • Posted in:
    Privacy & Data Security
  • Blog:
    Data Privacy Dish
  • Organization:
    Greenberg Traurig, LLP
  • Article: View Original Source

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