DPC Announces Public Statement Regarding LinkedIn’s Artificial Intelligence Model Training Plan

The Irish Data Protection Commission (“DPC”)’s announcement (“Announcement”) regarding LinkedIn’s generative artificial intelligence model training processes was published on the DPC’s official website on 07 November 2025.

According to the Announcement;

  • It is stated that LinkedIn’s plan to train its proprietary artificial intelligence models by using the personal data of LinkedIn members located in the EU/EEA was communicated to the DPC.
  • It is indicated that, following a detailed review carried out by the DPC, various risks and areas of concern associated with the proposed personal data processing activities were identified and communicated to LinkedIn.

In this context, the measures adopted by LinkedIn are summarised as follows:

  • Transparency notices concerning the personal data to be processed for the purpose of model training and users’ right to object will be improved.
  • The scope of the personal data to be processed will be reduced by narrowing both the categories of data to be used and the time period from which such data will be drawn.
  • Measures designed to prevent the personal data of users under the age of 18 from being used for model training will be strengthened.
  • Filtering mechanisms will be implemented to prevent the processing of potentially sensitive information that may be shared on certain LinkedIn Pages and Groups, including trade union-related content.
  • Mandatory documentation under the GDPR, such as the Legitimate Interest Assessment, the Data Protection Impact Assessment and the Compatibility Assessment, will be further developed and provided in a more detailed manner.

It has been required by the DPC that LinkedIn prepare a report within five months following the commencement of the processing, which will include updated evaluations regarding the efficacy of the measures and safeguards introduced.

It has been stated by the DPC that LinkedIn’s compliance with the GDPR will continue to be monitored and that additional regulatory powers will be exercised if deemed necessary.

You can access the full text of the Announcement here.

 

Kind regards,

Zumbul Attorneys-at-Law

info@zumbul.av.tr


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