Data Provenance and Training-Data Governance

EU AI Act requires machine-readable opt-out standards for GPAI by August 2025 (via EU Copyright Directive TDM exception). California AB 2013 (signed 2024) — Generative AI training-data transparency requires developers to publish a summary of datasets with 12 mandated fields. 2025 DPA alignment on legitimate interest: Irish DPC (21 May 2025) accepts Meta's LLM training on first-party public EU/EEA adult content with safeguards after EDPB opinion; Cologne Higher Regional Court (23 May 2025) dismisses injunction; Hamburg DPA drops urgency; UK ICO (23 September 2025) issues a positive regulatory response to LinkedIn's AI-training safeguards (transparency, simplified opt-out, extended objection windows) and continues monitoring — not a formal clearance. Brazilian ANPD (2 July 2024) suspended Meta's processing over insufficient information transparency; the preventive measure was lifted on 30 August 2024 after Meta submitted a compliance plan. Key irreversibility problem: cookie-consent frameworks are designed for real-time, reversible tracking; once data is in model weights, surgical erasure is impossible — no practical GDPR right-to-erasure for trained neural networks. Compliance window is at collection time. Data Provenance Initiative (dataprovenance.org, Longpre, Mahari, Lee et al., "Consent in Crisis", July 2024): large-scale audit shows rapid decline of the AI data commons as publishers add robots.txt restrictions.

Prerequisites: Phase 18 · 24 (regulatory), Phase 18 · 26 (cards)