life; genetic data; criminal history records; biometric information; and
information relating to race or ethnicity.
Second, the preceding principle highlights the particular risks
associated with unique identifiers and sensitive personal data,
but it does not imply that other types of personal data are safe
to upload. As a general rule, it is advisable not to upload personal
data of any kind. Where analysis of personal data is unavoidable,
such data should be pseudonymized. Pseudonymization refers to
a process in which certain personal identifiers—such as names or
personal identification numbers—are removed or replaced with
encrypted strings, so that individuals cannot be identified without
additional information that would allow the data to be re-linked to
the original source.
Third, even if data does not constitute personal data, particular
caution is required with respect to information that requires a
high level of security depending on its classification—namely,
confidential materials whose disclosure could cause harm if leaked.
Such information should not be entered into prompts. Examples
include interviews with victims, non-public minutes of meetings
concerning important decisions, and financial or accounting
records. Decisions about how to define security classifications,
the degree of trust that can be placed in AI providers, and the
organization’s tolerance for risk will necessarily vary depending on
each organization’s specific circumstances.
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