GDPR and AI: Where Article 5, Article 22, and Article 32 Reach Production AI Deployments
GDPR applies to AI deployments wherever the AI system processes personal data of EU residents. The applicable articles overlap with the EU AI Act but predate it and reach a broader surface. Article 5 imposes the lawfulness, purpose limitation, and data minimization principles. Article 22 limits automated individual decision-making. Article 32 imposes the security of processing obligation that the audit log is evidence against. This piece walks through the GDPR articles that reach production AI deployments, the specific obligations each creates, where most AI implementations fail the test, and the inspection-layer architecture that produces the evidence the data protection authority will accept.
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