Author
Parlamentul European și Consiliul
1 reading card from 1 book · 2016.
1 card
Regulamentul (UE) 2016/679 — GDPR · 2016
Pseudonymise at the tool boundary, re-identify at the end, keep the traces clean and the memory off.
Where personal data enters: retrieval, CRM and email tools, uploaded documents, tool outputs. Where it leaks: the model provider's logs, traces, memory, handoffs between sub-agents, outbound tools. The pipeline: classify and pseudonymise at the tool boundary (tokens of the form PERSON_1) before the text reaches the model; re-identify only in the final step, on your side; redact tool outputs down to the fields needed; short retention on traces (days, not forever), with spans scrubbed of personal data; per-user memory is opt-in, not default; processing terms with providers (no training on data, EU region) or on-prem for the special categories of Article 9; a data-protection impact assessment where the risk is high. Minimisation also shrinks the injection blast radius: what the model never saw cannot leak.
“The controller shall implement appropriate technical and organisational measures for ensuring that, by default, only personal data which are necessary for each specific purpose of the processing are processed.”