CNIL publishes new recommendations on the use of legitimate interest as a legal basis under GDPR for AI training

France’s Commission Nationale de l’Informatique et des Libertés (CNIL) has published a new set of recommendations on the use of legitimate interest as a legal basis under the GDPR for training AI technologies with personal data, particularly in the context of web scraping. These recommendations follow the opinion issued by the European Data Protection Board (EDPB) in December 2024, which acknowledged that legitimate interest may serve as a valid legal basis for this type of processing, provided certain conditions are met. The CNIL’s guidance aims to clarify these conditions further, providing practical examples of appropriate safeguards and highlighting specific circumstances in which legitimate interest may be applicable.

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