United Kingdom: Closed consultation on ICO inquiry into allocating controllership across the generative AI supply chain

On 18 September 2024, the United Kingdom's Information Commissioner's Office (ICO) closed the public consultation on its inquiry into allocating controllership across the generative AI supply chain. The inquiry is the fifth call for evidence in the generative AI consultation series and requested information on the allocation of roles and responsibilities in the generative AI supply chain so generative AI developers and deployers can fulfil their data protection obligations as a controller, joint controller or processor. In particular, the inquiry requested evidence on the influence and control organisations have over determining the means and purposes of distinct processing activities; evidence on how organisations have undertaken or instructed other entities to undertake, fine-tuning of a generative AI model; and evidence on specific elements organisations releasing “open-access” models make accessible.