A fictional lender considers account history and social-media data.
10–15 min · 0/4 steps complete
Start here / A workplace decision
Map the processing before selecting a tool
A fictional lender considers account history and social-media data.
The project team has an AI risk label but no defined processing purpose.
Before you read / Think it through
In “Map the processing before selecting a tool”, what would you check or do first?
Pause and form your answer, then compare the reasoning. This reflection is not scored.
Compare the reasoning
Identify purposes, necessity and the applicable lawful basis separately.
The ideas below give you a method for this decision. Then work through the rest of this case and try the decisions yourself.
Part 1 of 4 Learn the ideas
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Parallellegalframeworks
AI Act compliance does not displace the GDPR.
Personal-data processing needs its own lawful assessment.
In the workplace
A system may be low risk under one framework yet high risk for privacy. Avoid treating a product badge as permission to process.
Remember this
Reuse evidence but map separate requirements.
The workplace case
YOUR CASE / AI AND DATA PROTECTION
A lender wants to combine applicants' account histories with social-media data to generate a credit score and automatically reject applications below a threshold. The supplier says the AI Act classification covers privacy. Staff propose collecting ethnicity data to test fairness without further review.
Quick reference / five key ideas
Parallel legal frameworks
Reuse evidence but map separate requirements.
Purpose and lawful basis
Consent is neither universal nor always valid at work.
Necessity and minimisation
Limit retention and secondary use.
Special categories and bias
Strict necessity, safeguards and limits must be documented.
Roles and supplier contracts
Assess independent uses by the supplier separately.