Risk and exam

Shareable reference

Settle data rights before the next training or scale gate

A living impact assessment: purpose, lawful basis, training versus inference, vendor sub-processing, and what happens if a subject objects after go-live.

A practical example

What this looks like in the business

A firm wants to fine-tune or prompt a vendor model on five years of customer cases, then roll it from one desk to the network. Legal and the DPO need a live assessment before processing starts: purpose, lawful basis, training versus inference, special-category risk, access and erasure paths, vendor sub-processing, and what happens if a subject objects after go-live. Scaling without a rights path is the failure, not missing a logo on a privacy notice.

What you leave with. A data-rights map and the uses that are allowed now.

Not this. A privacy notice refresh or a vendor GDPR-ready checkbox. Calendar for this class of work is measured in weeks, not hours.

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