On 9 December 2025, the Data Protection Authority (IMY) released a report on personal data processing for training artificial intelligence models in custody matters. The project, conducted with the law firm Familjens Jurist within the IMY regulatory sandbox, evaluated the use of custody case data to predict high-conflict scenarios. The inquiry focused on whether further processing for AI training complies with General Data Protection Regulation (GDPR) principles, specifically purpose limitation. The report states that synthesising personal data constitutes further processing and is generally compatible with original purposes, provided it adheres to GDPR requirements. Given the sensitive nature of custody information, the IMY noted that additional safeguards, such as opt-out mechanisms for data subjects, are necessary. With safeguards, the IMY concluded that training models with synthetic data could be considered permissible.
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