Training on Personal Data Without Consent
未取得同意即以個資訓練
When an organization uses accumulated user data from an existing service to train a new model without obtaining separate consent; due to unmitigated control gaps, after users raise objections, the authority opens an inquiry into whether the use exceeded the original collection purpose, and the organization faces demands to cease processing and delete the model, triggering compliance exposure and operational reputational costs.
Framework Mappings
Risk Treatment & Implementation Guidance
Review the legal basis of data at training-project initiation, obtaining fresh consent or confirming a lawful basis where use exceeds the original purpose; Standardize consent design so training use is clearly explained and revocable; Retain consent evidence and purpose assessments for regulatory examination