Sovereignty

Generative AI & GDPR

The GDPR (General Data Protection Regulation) governs every processing operation involving personal data. Generative AI inside a local authority often handles citizens' data, so compliance is not optional. A sovereign AI makes it easier from the design stage onwards.

Informational content: this does not constitute legal advice.

The GDPR watch points for an AI system

  • Legal basis & purpose

    Every processing operation must rest on a legal basis (a public interest task for a local authority) and on a specified purpose. The AI assistant must have a documented scope of use.

  • Impact assessment (DPIA)

    An innovative technology processing sensitive data on a large scale triggers the DPIA obligation (art. 35). To be carried out before going live, together with the DPO.

  • Right to erasure inside a RAG

    In a RAG system, a document is split into vectorised fragments. Deleting the file is not enough: you need a procedure that also purges the vectors and the histories. A technical point that we industrialise.

  • Minimisation & retention

    Process only what is necessary, and define retention periods. Our GPU instances are stateless ; minimisation and erasure must be verified for each layer, including logs and backups.

  • Processors (art. 28)

    A clear contractual chain between the data controller, the provider and the hosting companies. EU hosting means no transfer outside the Union to be framed.

Where your data lives inside a RAG

An indexed document is split and then vectorised into the database. Deleting the source file removes neither the vectors nor the histories: erasure (art. 17 GDPR) must purge the entire chain.

1 · INDEXING : once only Your documents PDF · Office · OCR Splitting into extracts Embeddings vectorisation Vector database your knowledge query extracts (context) 2 · FOR EVERY QUESTION Question Embedding question → vector Search top-K similar LLM Enriched prompt: question + extracts Sourced answer with citations
A technical point that we industrialise: an erasure procedure that purges the file, its vectors and the histories.

How a sovereign AI helps

  • Data hosted in the EU, under European law alone
  • Minimisation by design (ephemeral model GPU server, deleted every evening)
  • Documentation ready for the DPO and the DPIA
  • Data pseudonymisation before sending to third-party APIs: experimental, in testing

Official sources

Build compliance into your AI project

We supply the compliance documentation and support your DPO. See also the EU AI Act.

Data protection: scope and status

The pseudonymisation gateway for external APIs is experimental and in testing; it is not advertised as production-ready. The mapping table allows restoration: data remains personal and GDPR still applies. Test detection and re-identification on the actual corpus.

CNIL: anonymisation / pseudonymisation

Responsibilities to validate

Documentation supports the controller and DPO for the actual processing. A public-interest task requires a legal basis in law and processing necessary for that task; it is not universal. A GDPR DPIA and an AI Act fundamental-rights impact assessment are distinct. Human oversight alone does not rule out high-risk classification.

CNIL: mission d’intérêt public