December 3, 2025

Legitimate Interests for Data in AI Training – The DPO Perspective

Since 2019, CIPL has been spearheading work to interpret the legal basis for processing personal data under data protection laws as well as apply data protection laws and principles to AI technologies.

Building on this, CIPL has spent the last year convening a select group of Data Protection Officers from leading companies in an initiative called ‘DPO Forum @CIPL’, which has enabled DPOs to exchange insights, discuss best practices, analyze emerging challenges, and contribute informed practice-oriented perspectives to the broader policy and regulatory discourse.

Our paper ‘Legitimate Interests for Data in AI Training – The DPO Perspective’ distills discussions from the DPO Forum @CIPL and explores the practical application of the legitimate interest legal basis from processing personal data in the context of AI.

The paper seeks to:

  • Underscore that legitimate interest is often the most appropriate ground for data processing in AI training, enabling responsible and accountable innovation;
  • Share DPOs’ practical experiences and considerations of the specific compliance steps in applying the legitimate interest legal basis, including the Legitimate Interest Assessment (LIA) in the context of AI training; and
  • Contribute to the development of future best practices in the implementation of legitimate interest and to inform the stakeholders, including regulators, of the expectations of success criteria in the application of legitimate interest for data processing in AI development and deployment.

Legitimate Interests for Data in AI Training - The DPO Perspective

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