Marcus Belke
CEO of 2B Advice GmbH, driving innovation in privacy compliance and risk management and leading the development of Ailance, the next-generation compliance platform.
More and more AI use cases are processing personal information, from customer data and employee details to sensitive analyses. This automatically brings the obligations of the GDPR into force: every AI project involving personal data must be recorded in the register of processing activities (VVT) and, depending on the risk, undergo a data protection impact assessment (DPIA). Those who do not act with foresight here risk data protection violations and project stoppages. The solution: AI governance and data protection compliance hand in hand. An integrated approach that seamlessly combines an AI inventory, a processing directory and DPIA processes. This way, innovation and GDPR compliance are not contradictory, but in harmony.
Interface between AI inventory and processing directory
A central AI inventory of all applications is the starting point for good AI governance. This records all of the company's AI systems and use cases with their purposes, data sources and controllers. At the same time, Article 30 GDPR prescribes a record of processing activities (RoPA) for all personal processing activities. This is a structured register that shows who processes which data, where and for what purpose. These two areas (AI inventory and data protection register) should not exist separately. Ideally, all AI processing with a personal reference should be directly linked to the processing register, for example via a technical interface.
In practice, this means that when a department creates a new AI use case, the relevant information (e.g. purpose, data categories, storage location) is automatically recorded in the VVT or linked to an existing entry. This makes it possible to see at an early stage whether and which personal data an AI system uses and whether a data protection impact assessment (DPIA) may be necessary.
This approach prevents gaps: No AI project runs „under the radar“ of data protection and all AI-related processing can be found seamlessly in the VVT. A well-maintained VVT is more than just bureaucracy, as it becomes a control instrument that helps to identify risky data processing at an early stage and then evaluate and address it.
Automated data protection impact assessment for AI projects
Many AI applications are considered high-risk under data protection law, as they rely on profiling, large amounts of data or novel algorithms, for example. The supervisory authorities emphasize that AI processing generally requires a data protection impact assessment (DPIA), as they are often classified as high-risk activities. Instead of carrying out this obligation manually and late in the project, it should be automated and initiated at an early stage as part of AI governance.
In concrete terms, this means As soon as the AI inventory indicates that a use case processes personal data or fulfills certain risk criteria, the DPIA process is automatically started. Modern AI management tools such as „Ailance AI governance“ integrate this step directly into the workflow: an AI use case can only be fully approved once the required data protection impact assessment has been carried out and documented. Risk-controlled workflows ensure that different checks are carried out depending on sensitivity. If a use case contains personal data, the system automatically starts the DPIA; in the case of high risk, even with additional check steps.
This automation reduces time-consuming loops and ensures that reliable evidence is produced for audits. In addition to compliance security, the automatic DPIA trigger also brings efficiency gains: companies that have digitized their data protection impact assessments report 60 to 80 percent faster processing and a multiplication of the cases covered per data protection team. It is important that the data protection officer remains involved, for example by being consulted by the system for each new DPIA and releasing the results. In this way Data protection implemented by design: No AI system goes live without risks being assessed and suitable protective measures being taken.
Synergies: AI governance as a data protection enabler
Close integration of AI governance and data protection compliance generates enormous synergies. AI governance becomes an enabler for data protection and vice versa. On the one hand, existing data protection processes are integrated into the AI processes so that they no longer have to run in parallel. A good governance solution docks onto existing processes, such as the DPIA procedure and the processing directory, and maps the same roles and responsibilities as the other compliance structures. On the other hand, AI governance gains depth through the data protection perspective: principles such as data minimization, purpose limitation and access restriction are already taken into account when planning an AI project. The result is AI systems that are developed with data protection built in from the outset. Privacy by design is anchored technically and organizationally.
At the same time, data protection officers and compliance officers benefit from the fact that AI projects are transparently recorded in the inventory and have meaningful documentation (e.g. model maps). Instead of laboriously searching for information, they receive information at the touch of a button about what data a model uses, for what purpose and what risks have been identified. Monitoring is made easier: dashboards in the AI governance platform can show, for example, which use cases have undergone a data protection impact assessment, which are considered critical or where reviews are pending.
This creates cross-divisional transparency and prevents data protection from only taking place in separate silos. Overall, this creates a comprehensive governance approach that covers the use of AI and the obligations under the GDPR at the same time. Companies can therefore drive forward innovative AI solutions without losing sight of data protection and compliance. Data protection is thus transformed from a brake on innovation into a co-creator: integrated AI governance increases the trust of users and supervisory authorities and reduces the risk of unpleasant surprises.
Practical tips for interlinked AI and data protection governance
The combination of AI governance and data protection pays off. But how can it be implemented in practice? Finally, some tips on how you can dovetail data protection and AI governance from a technical and procedural perspective:
- Maintain a central AI register: Create a company-wide inventory of all AI applications. The purpose, data types, persons responsible and risk level should be documented for each AI use case. This register forms the basis for all further compliance steps.
- Ensure VVT integration: Link the AI inventory to your record of processing activities (RPA). New AI projects that use personal data should automatically end up in the VVT. This allows you to comply with the GDPR documentation obligation and recognize early on when additional checks are required.
- Automate DSFA workflow: Define rules for when a data protection impact assessment should be triggered (e.g. for certain data categories or a high risk classification). Use tools or scripts that start this process automatically and monitor the progress. Involve the data protection officer in the approval process to ensure a professional assessment.
- Define joint responsibilities: Establish clear roles for AI projects in which the legal/compliance team and IT/AI team work together. For example, an AI project can only go live once both the technical manager and the data protection officer have given the green light. Such dual approvals, which are logged in the system, increase reliability and acceptance.
- Continuous review and training: Interlocking also means remaining attentive during ongoing operations. Set up regular reviews or re-audits in which AI applications and their data protection measures are reassessed. Reminder functions in the governance tool can trigger these reviews automatically. Also train project managers and developers to think about data protection requirements from the outset - the tool support does a lot for them, but does not replace the basic understanding.
These measures make data protection and AI governance one and the same: compliance by design becomes part of everyday life and your company can take advantage of the opportunities offered by artificial intelligence without coming into conflict with the GDPR. Combining data protection and AI governance today creates the basis for trustworthy AI systems and long-term business success.
Experience for yourself how integrated governance works
With Ailance AI Governance, you combine VVT, DSFA and AI inventory in one workflow - automated, traceable, scalable.
Whether data protection officers, IT managers or project managers: everyone can see at a glance where approvals stand, which risks have been assessed and which use cases still need to be checked.
Marcus Belke is CEO of 2B Advice as well as a lawyer and IT expert for data protection and digital compliance. He regularly writes about AI governance, GDPR compliance and risk management. You can find out more about him on his Author profile page.
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