EDPB legitimate-interest assessment for AI training (interest, necessity, balancing); high bar to claim a trained model is anonymous
3-step testobserved
| Value kind | observed — Reported measurements, counts, and specifications keep the precision and scope stated by their source; an exact specification is not treated as a range. |
|---|---|
| Scope | Purpose/interest, necessity and balancing where legitimate interests is relied upon; not an instruction that AI training generally uses that basis. |
| As of | 2024-12-17 |
| Source | European Data Protection Board, Opinion 28/2024, adopted 17 December 2024 (cover). · Executive summary, pages 2–3; Section 3.3.2: legitimate interest, necessity, and balancing tests |
| Review | checking…review by 2026-12-05 · standard cadence |
| Recorded changes | last 2026-09-16 · 2 revisions tracked |
| Claim id | edpb-legitimate-interest-assessment-for-ai |
Where the guide uses it
← Full numbers register — every date-stamped figure in the guide, with revision history.