ChatGPT, Large Language Models (LLMs), and Data Privacy: What businesses need to know now!
? Copyright 2023 Debbie Reynolds Consulting, LLC

ChatGPT, Large Language Models (LLMs), and Data Privacy: What businesses need to know now!

Welcome to "The Data Privacy Advantage Newsletter" which will be a monthly resource hub of practical information, advice, and content that will help organizations make Data Privacy a business advantage.

ChatGPT, Large Language Models (LLMs), and Data Privacy: What businesses need to know now!

ChatGPT , a general-purpose (AI) Large Language Model (LLM) created by OpenAI , is capable of?performing a wide range of digital tasks and has taken the world by storm.?The chatbot allows anyone to ask questions and receive responses using natural language.?Since the release of this chatbot to the public in November 2022, ChatGPT now has over 100 million users and has received over 1 billion visits to the site. As AI progresses, businesses are leveraging the power of LLMs such as OpenAI's ChatGPT to automate tasks, create virtual assistants, improve customer service, create documents, and generate content. While LLMs, like ChatGPT, offer significant benefits, they pose unique challenges to Data Privacy. There are three key points businesses must consider ensuring they maintain Data Privacy while utilizing LLMs:

  • Avoid adding sensitive and confidential information to LLMs
  • Secure your internet-exposed data to avoid ingestion into LLMs
  • Be aware of legal obligations that apply to third-party uses of LLMs

Avoid adding sensitive and confidential information to LLMs

LLMs like ChatGPT are trained on vast amounts of publicly available text data, including websites, books, and articles. However, this means that any sensitive information inadvertently exposed to the Internet may be incorporated into the LLM's training data. Consequently, businesses must be diligent in keeping confidential information out of LLMs.

To prevent sensitive data from being absorbed by LLMs, businesses should:

  • Implement strict data access and sharing policies for employees and partners. Only authorized personnel should be allowed to access sensitive information, which should never be shared publicly or in unsecured channels.
  • Use data anonymization techniques when sharing data with third parties, such as replacing personally identifiable information (PII) with pseudonyms or aggregation.
  • Avoid using LLMs to process sensitive data, as the outputs generated by these models may inadvertently reveal confidential information. Instead, consider utilizing specialized privacy-preserving AI solutions designed to handle sensitive data.

Secure your Internet-exposed data to avoid ingestion into LLMs

LLMs may inadvertently ingest sensitive information that businesses unintentionally expose to the Internet based on how LLMs gather data from the Internet.?

To mitigate this risk, businesses should take the following steps to secure their Internet-exposed data:

  • Regularly audit and monitor public-facing websites and applications for vulnerabilities and accidental data exposure. Remediate any discovered issues promptly.
  • Implement strong authentication and access control measures for all web applications, especially those containing sensitive information. This includes multi-factor authentication, role-based access control, and single sign-on solutions.
  • Use encryption for data in transit and at rest. This ensures that even if sensitive information is accidentally exposed, it is unlikely to be useful to unauthorized parties or ingested by LLMs.
  • Monitor third-party services and platforms that host or process your data. Ensure they maintain appropriate security measures and have a track record of protecting sensitive information.

Be aware of legal obligations that apply to third-party uses of LLMs

Businesses must also be aware of the legal implications of using LLMs, as they may be subject to various privacy regulations depending on their location and industry.?

Some key legal obligations to consider include the following:

  • Complying with data protection laws, including but not limited to the General Data Protection Regulation (GDPR) in the European Union, the AI Act in the European Union, and the California Consumer Privacy Act (CCPA) in the United States. These regulations mandate strict data handling practices, including obtaining user consent, providing transparency, and allowing users to access, correct, or delete their data.
  • Adhering to industry-specific regulations, such as the Health Insurance Portability and Accountability Act (HIPAA) for healthcare or the Payment Card Industry Data Security Standard (PCI DSS) for payment processing. These regulations impose additional requirements on businesses to protect sensitive information and may also limit the use of LLMs in certain contexts.
  • Ensuring that third-party AI vendors, including LLM providers, comply with applicable privacy regulations. This includes conducting due diligence when selecting vendors, reviewing their privacy policies, terms of service, and data practices, and including data protection clauses in contracts and agreements.
  • Developing comprehensive Data Privacy Impact Assessments (DPIAs) when implementing LLMs. This assessment should identify and evaluate the potential risks associated with using LLMs and outline the necessary steps to mitigate those risks.
  • Training employees on Data Privacy best practices and the responsible use of LLMs. Staff members must understand these AI technologies' potential risks and legal obligations.
  • Maintaining an incident response plan to address potential data breaches or privacy violations. This plan should include clear procedures for reporting and investigating incidents and steps to remediate and notify affected parties, as required by law.

As businesses embark upon new ways of leveraging technologies, businesses must always be vigilant in safeguarding sensitive and confidential information while utilizing the benefits of LLMs like ChatGPT. By implementing robust data access and sharing policies, securing internet-exposed data, and staying informed about legal obligations, organizations can harness the power of LLMs without compromising Data Privacy. By doing so, businesses can enjoy the benefits of leveraging new technologies like LLMs while making Data Privacy a Business Advantage.

Do you need Data Privacy Advisory Services? Schedule a 15-minute meeting with Debbie Reynolds the Data Diva.

The Pact Data Privacy Trust Framework

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Debbie Reynolds, "The Data Diva," launched the PACT "Data Privacy" Trust Framework & Scorecard. This Framework can evaluate regulatory and business risk and the Trust of individuals around "Data Privacy". This is a gut check for organizations of all sizes to rate and triage their "Data Privacy" challenges. This Framework addresses Purpose, Alignment, Context, and Transparency.?Watch this video to learn the basics as Debbie Reynolds explains the PACT Data Privacy Trust Framework & Scorecard in 6 minutes.

Download our four-page PACT Framework Document here

Visit our website to learn more about the?PACT Data Privacy Trust Framework & Scorecard.


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Do you need a Data +Privacy +Technology Workshop? Here are the top ten most requested Data Privacy Workshops for 2023:

  1. Generative AI and the Future of Cybersecurity and Data Privacy in the Enterprise
  2. Understanding Digital Assets: An Introduction to Cybersecurity and Data Privacy Concerns for Business
  3. Web 3.0 and the Evolving Landscape of Cybersecurity and Data Privacy for Businesses
  4. The Importance of Data Literacy in the Era of Cybersecurity and "Data Privacy"
  5. Navigating the Landscape of Emerging Data Types: Key Cybersecurity and Data Privacy Insights for Businesses
  6. Future Threats to Cybersecurity and Data Privacy: The importance of Post-Quantum Cryptography for Businesses
  7. Navigating the Cybersecurity and Privacy Challenges of the Internet of Things
  8. Navigating the Cybersecurity and Data Privacy Implications of Facial Recognition and Other Biometric Technologies
  9. Navigating the Cybersecurity and Data Privacy Implications of the Metaverse: A Business Guide to Virtual and Augmented Reality
  10. The Five Fundamentals of Data Privacy and Data Protection Regulations

Each 120-minute workshop structure includes:

  • Introduction and overview (10 minutes)
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  • ?Part B - Main presentation (35 minutes)
  • ?Part B - Breakout group activity - Case Study Scenario #2 (10 minutes)
  • ?Question & Answer?- group discussion and wrap-up (15 minutes)

Materials Provided:

  • Presentation Materials (PDF)
  • Take Away Checklist (PDF)
  • List of Additional Resources (PDF)

Do you need a workshop? Schedule a 15-minute meeting with Debbie Reynolds the Data Diva to discuss your needs.

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Did you know that the Data Diva Talks Privacy Podcast has listeners in 79 countries and is ranked globally in the top 5% of podcasts? Here are more of our accolades:

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Many thanks to the press organizations and reporters who seek my commentary on important events around "Data Privacy". Also, here are links to some of my other media collaborations. Here is a collection of a few of my 2023 media mentions and collaborations:

  • Many thanks to Tonal Carreras for his review of the Privacy Pros Podcast interview with Debbie Reynolds and Jamal Ahmed
  • Many thanks to Ketch for inviting me to speak at the Chicago "Privacy Matters" Dinner and Cindy's. It was a blast!
  • Debbie Reynolds "The Data Diva" spoke on a webinar called "Women and Digital Privacy: Protecting Health Data Post-Roe" with Kayte Spector-Bagdady , Interim Co-Director at the Center for Bioethics and Social Sciences in Medicine and an Assistant Professor of Obstetrics and Gynecology at the University of Michigan Medical School, and Sara Jacobs, Congresswoman for California's 51st Congressional District. Sponsor of the My Body, My Data Act and the Secure Access for Essential Reproductive (SAFER) Health Act

For a full list of media mentions, please see our?website media mention section.

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Please join?Debbie Reynolds?“The Data Diva” on?Tuesday, April 18, 2023, and Wednesday, April 19, 2023, from 11:00 a.m. until 5:00 p.m., Eastern Time each day for an open-to-the-public virtual meeting of the 16-member Internet of Things Advisory Board (IoTAB) appointed by the?U.S. Department of Commerce?(USDOC) and The?National Institute of Standards and Technology (NIST).?

All meetings of the IoTAB will be open to the public. A registration page is available for the April meeting sessions (see the link below). An agenda will be provided once it has been finalized; the overall scope of the agenda will be approximately:

?? Board Introductions and Member Activities

?? Overview of the charter, scope, and expectations

??Overview of legislation creating the IoT Advisory Board

??Framework proposals for recommendations report

??Advisory Board member statements on challenges and barriers to IoT technology adoption

??Discussion of topics raised in member statements

??Outside speakers on challenges and barriers to IoT adoption

??Public Comment

??Board Discussion on Recommendations.

To register to attend the virtual event or in person on one or both days register here:?https://nist-secure.webex.com/webappng/sites/nist-secure/webinar/webinarSeries/register/20c4eb5a75e44cde82e50105a942ebab

IoTAB April 18 & 19, 2023 Meeting

April 11, 2023, 5:00 PM – deadline for requesting to speak to the IoT Advisory Board at the April Meeting

April 12, 2023 – deadline for in-person registration for the IoT Advisory Board Meeting (limit of 50 registered attendees) – email Barbara Cuthill ([email protected]) with your name, email, affiliation, and if you are a US citizen. (As a Federal facility, we have to record additional information for non-US citizens.)

To email public comments for consideration by the IoTAB, please email Barbara Cuthill, The IoT Advisory Board Secretariat prior to the meeting by April 11, 2023, at 5:00 p.m. EST. by 5:00 pm Eastern time at?[email protected]

  • Individuals who submit comments may have an opportunity (on a first-come, first-served basis) to present and discuss them at the meeting during the afternoon of the April 19th, 2023 meeting session (presenters will be limited to 5 minutes each). The public is also invited to send written statements for the board’s consideration at any time; however, such statements will not be presented at the meeting. More information regarding comments and written statements are published in the Federal Register Notice.


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Hitoshi Kokumai

Advocate of Identity Assurance by Citizens' Volition and Memory. Founder and Chief Architect at Mnemonic Identity Solutions Limited

1 年

I am pleased to see it emphasised that, to prevent sensitive data from being absorbed by LLMs, businesses should “Implement strict data access and sharing policies for employees and partners. Only authorized personnel should be allowed to access sensitive information, which should never be shared publicly or in unsecured channels.” While identity authentication alone, however solid it may be, cannot satisfy the sufficient condition for the defense of data privacy, it is definitely one of the necessary conditions for the objective. And, among the necessary conditions for the solid digital identity is that it involves citizens’ volition and memory.?More specifically, it’s‘ imperative to involve secret credential’ that citizens present with their volition to present it. The secret credential is ‘Remembered Password’ in most cases.

Alexandre MARTIN

πολυμαθ?? ? Times of AI ? Analyste d'Affaire en IA ? éditorialiste & Veille stratégique ? AI hobbyist ethicist - ISO42001 ? Techno-optimiste ?

1 年
William Wallace Belt Jr., Esq., CIPP/US/E CIPM

Managing Director at Complete Discovery Source

1 年

Excellent article Debbie Reynolds.

Thank you Debbie Reynolds for the insights and the post.

Toma? Vidonja

Helping manufacturing companies to digitaly transform their businesses

1 年

A must reading post for every business owner, not only IT department, to get an undersranding why AI (MLL etc.) matters and how it impacts each single business in terms of data privacy and security. As many belive it's only ChatGPT, I wonder Debbie, how should businesses react in terms of many other AI applications? ??https://writesonic.com/blog/chatgpt-alternatives/

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