Privacy policy discloses AI data processing
Why it matters
GDPR Articles 13 and 14 require data controllers to inform users about third-party processors and the purposes for which their data is shared — at the time of collection. CCPA §1798.100 similarly mandates disclosure of data sharing practices. A privacy policy that makes no mention of AI providers, large language models, or the categories of data sent to them is a material omission that creates regulatory exposure and undermines user trust. When a breach or complaint triggers regulatory review, an undisclosed sub-processor is one of the clearest indicators of non-compliance.
Severity rationale
High because a privacy policy that omits AI data processing is a documented regulatory violation under GDPR Art. 13/14 and CCPA §1798.100, creating direct liability without requiring any breach to occur.
Remediation
Add a dedicated AI data processing section to your privacy policy. Name the provider, describe what data categories are sent, the purpose, and the retention period.
## AI Features
Our application uses AI services to power [feature name]. When you use
these features, your input is sent to [Provider Name] for processing.
[Provider Name] processes this data under a Data Processing Agreement
with us and their own privacy policy: [link]. We do not use your data
to train AI models [or: model training opt-out is available in Settings].
AI conversation history is retained for [X days / the session duration].
If you use multiple providers (e.g., OpenAI for chat, Anthropic for summarization), list each one separately. Link to their privacy policies. Revisit this section whenever you add or switch AI providers.
DetectionPro
The detection method for this pattern is part of AuditBuffet Pro.
The full method (what to look for, pass and fail conditions, and how results get reported) ships inside the AI Data Privacy Audit. The pattern definition, severity rationale, and remediation remain openly licensed under CC-BY-4.0.
External references
- gdpr · Art. 13 — Information to be provided where personal data collected from data subject
- gdpr · Art. 14 — Information where personal data have not been obtained from the data subject
- ccpa · §1798.100 — Right to know / privacy policy disclosure
- nist-ai-rmf:1.0 · GOVERN 6.1 — Policies for responsible AI in third-party contexts
Taxons
History
- 2026-04-18·v1.0.0·Initial import from ai-data-privacy·automated