Ireland: Announced Irish Data Protection Commission investigation into Google AI model for alleged violations of GDPR data protection impact assessment

On 12 September 2024, the Irish Data Protection Commission (DPC) announced that they launched a statutory cross-border investigation into Google Ireland Limited under Section 110 of the Data Protection Act 2018. In particular, the DPC will investigate whether Google complied with its obligations to conduct a Data Protection Impact Assessment (DPIA), as required under Article 35 of the General Data Protection Regulation (GDPR), before processing personal data of EU/EEA individuals in developing its AI model, Pathways Language Model 2 (PaLM 2). A DPIA is required when processing personal data that may pose a high risk to individuals' rights and freedoms, a risk which is particularly heightened when new technologies are involved.