The development, procurement and deployment of AI systems involving the processing of personal data raises significant risks to data subjects’ fundamental rights and freedoms, including but not limited to privacy and data protection. The principle of accountability enshrined in the UK GDPR and the EU GDPR require Data Controllers to identify and mitigate these risks, as well as to demonstrate how they did so. This is especially important for AI systems that are the product of intricate supply chains often involving multiple actors processing personal data in different capacities.
The European Data Protection Supervisor (EDPS) has just released an important new guidance document to help organisations conduct data protection risk assessments when developing, procuring, or deploying AI systems. It focuses on the risk of non-compliance with certain data protection principles for which the mitigation strategies that controllers must implement can be technical in nature – namely fairness, accuracy, data minimisation, security and data subjects’ rights.
Key sections of the document address:
- the risk management methodology according to ISO 31000:2018
- the typical development lifecycle of AI systems as well as the different steps involved in their procurement
- the notions of interpretability and explainability
- an analytical framework for identifying and treating risks that may arise in AI systems, structured according to the data protection principles potentially affected.
The EDPS has issued this guidance in his role as a data protection supervisory authority for EU institutions. However it is a very useful document for any organisation deploying AI and which requires guidance on how to systematically assess the risks from a data protection perspective.
Our AI Governance Practitioner Certificate course, is designed to equip Information Governance professionals with the essential knowledge and skills to management the risk of AI deployment within their organisations. This year 50 delegates, from a variety of backgrounds, have successfully completed the course, giving great feedback.
The first course of 2026 starts on 8th January. Places are limited so book early to avoid disappointment. If you require an introduction to AI and information governance, please consider booking on our one day workshop.

