Cybersecurity Policy Report, Joint EU Consultation on AI, Privacy Joined by Croatia, (Aug 11, 2025)
By Tony Foley
The Croatian data protection agency (AZOP) has invited interested parties to participate in a consultation being conducted as part of a joint European Union initiative on the protection of personal data in the context of artificial intelligence.
In a news release announcing the move, the agency noted that the consultation was launched by Germany’s Federal Commissioner for Data Protection and Freedom of Information (BfDI) last month (CPR, July 11). AZOP said it joined the initiative to contribute to the development of a legal and technical framework across the EU. The consultation seeks to gather opinions, practical experiences, technical assessments, and normative considerations from experts and organizations from various fields, with an emphasis on the development and use of large language models (LLMs). It consists of an eight-question survey, which interested parties must complete and submit by Aug. 30.
In its recently published opinion on personal data processing in the context of AI models, the European Data Protection Board (EDPB) emphasized that LLMs were able to memorize personal data if they were trained on such, AZOP said. For purposes of the consultation, “memorization” is interpreted more broadly than its usual scientific understanding, meaning that in addition to verbatim reproductions, it includes analog reproductions that could contribute to the identification of an individual and thus become relevant from a data protection perspective.
AZOP noted that the EU’s General Data Protection Regulation (GDPR) did not apply to AI models trained exclusively on anonymous data but added that, due to the volume and nature of data typically used to train LLMs, complete and total anonymization often was unachievable. The main conclusions of the consultation will be consolidated in a final report that will be published in anonymous form on the AZOP website.
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