Germany: Mention of coordinated investigation into ChatGPT’s data processing practices

On 11 April 2023, the State Commissioner for Data Protection and Freedom of Information in North Rhine-Westphalia published a press release regarding ChatGPT, mentioning a coordinated investigation of the Data Protection Conference (DSK) concerning the data processing practices of ChatGPT. The DSK launched a coordination investigation involving all the federal and all state data protection authorities, due to the importance of the application. Normally, it is the responsibility of the state data protection supervisory authorities to address data protection issues. In its press release, the State Commissioner expressed it would require further information to make a data protection assessment on ChatGPT, including specific details on the data sources, the algorithms behind the automated data processing and the transfer of information to third parties with commercial interests.