AI Act: Requirements for General-Purpose AI Models

Any self-respecting Englishman or woman will tell you that, to make a really good cup of tea, the tea must steep in its teapot for a couple of minutes before pouring. Sometimes the same is true of regulatory guidance: to really get to grips with it, you need to let it steep in the back […]

AI Act: Requirements for General-Purpose AI Models

This article was first published in the IAPP’s AI Act series here.  It is republished here with minor editorial edits to improve readability. If you were to read the European Commission’s original AI Act proposal, published in April 2021, you would find it conspicuously devoid of references to general-purpose AI (“GPAI”). With the benefit of hindsight, […]

Joint controller relationships – Why the hate?

Upon its adoption in 2016, the GDPR introduced a provision specifically focussed on “joint” controllership, in Article 26.  While the notion of joint controllership was not new (the Article 29 Working Party discussed joint controllership under the old Data Protection Directive in 2010 guidance, for example), a legislative provision that expressly set out measures joint […]