The rise of large language models (LLMs) poses challenges to the applicability of data protection rules. There is a lot of debate about the question of whether or not LLMs themselves store personal data. Recently, the Hamburg Commissioner for Data Protection and Freedom of Information (Hamburg DPA)…

Data protection rules such as the EU's new General Data Protection Regulation (GDPR) apply to personal data. But what does personal data mean? According to the GDPR, ‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable…