With the rapid rise of artificial intelligence across Europe, the issue of RGPD compliance is coming back to the fore. The European AI Regulation (AI Act) and the RGPD impose a strict framework on companies regarding data protection, particularly when AI systems process personal data.
Any use of AI involving the processing of personal data must comply with the principles of the GDPR. This includes minimising data, being transparent about purposes, securing the data collected, and respecting the rights of data subjects. Companies must therefore ensure compliance both in their data processing and in their application of the RGPD.
The processing of personal data via AI models, particularly those involving automated decision-making, can have a significant impact on privacy. Article 22 of the GDPR sets clear limits to protect the fundamental rights of individuals when personal data is used in these systems.
The DPO (Data Protection Officer) plays a central role in ensuring compliance with the RGPD - managing databases, deleting irrelevant data collected, supervising processing. Every company must implement appropriate security measures to protect sensitive data and comply with its legal obligations.
Ensuring RGPD compliance in the development of AI
A continuous compliance process
Compliance with the GDPR is an essential and ongoing process for organisations developing or using AI systems. This involves documenting each processing activity, identifying the categories of data collected, defining clear purposes, and assessing the risks to data subjects' rights.
Companies must justify the relevance of the data used and avoid any excessive collection, in line with the principle of data minimisation. This applies both to sensitive data and to re-used datasets.
Protecting data throughout the AI lifecycle
Security by design is crucial: access controls, anonymisation or pseudonymisation, and strict monitoring of usage must be built in from the outset. AI training and inference data must be regularly reviewed and deleted when no longer required to comply with RGPD obligations.
Governance and responsibility
AI systems - especially those based on large-scale data - require strong governance. DPOs need to work closely with AI teams to oversee technical decisions and ensure GDPR compliance at every stage. This alignment supports innovation while protecting privacy and fundamental rights.
AI Act & RGPD: a converging regulatory framework
Two complementary frameworks
The European AI Act regulation aims to provide a framework for the development and deployment of AI, while the RGPD regulates the processing of personal data. Companies must comply with both, particularly for AI systems used in automated decision-making, behavioural analysis or biometric surveillance.
The role of CNIL in interpreting AI & RGPD
In France, the CNIL provides key recommendations on the application of the RGPD in AI contexts. It warns against the unregulated re-use of personal data without providing adequate information to data subjects, and recommends minimising the data collected as well as limiting their purposes in order to avoid surveillance or algorithmic discrimination.
RGPD compliance, a strategic advantage
Beyond being a legal obligation, RGPD and AI Act compliance offers companies an opportunity to gain the trust of customers, partners and users. Transparency, security and responsibility are becoming strategic pillars for sustainable digital growth.
Acting now: towards ethical, RGPD-compliant AI
Regulatory requirements around data protection and AI governance continue to grow. Data management is becoming strategic, and every processing operation must be justified, documented and secured. Failure to adapt exposes organisations to legal, financial and reputational risks.
DPOs must steer the compliance process, assess risks, document processing and support AI teams - ensuring that internal practice is aligned with European regulatory expectations, in a transparent approach to data subjects.
Conclusion: building responsible AI while ensuring RGPD alignment
With the widespread use of AI, companies no longer have a choice: they must comply with the RGPD, incorporate the requirements of the AI Act, and rethink the governance of personal data.
RGPD compliance is not just a legal obligation - it is a lever for credibility, differentiation and long-term competitiveness. Organisations need to manage personal data responsibly - focusing on the categories used, clear communication and transparency about all processing. Responsible data governance is at the heart of ethical and sustainable innovation.
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