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Ibero-American privacy regulators say vendors can't train AI on client data by default

Ibero-American privacy regulators say vendors can't train AI on client data by default
Image: PPC Land

The 29-page RIPD standards also treat inferred health or beliefs as sensitive data and say a bare "we use AI" notice does not inform people.

Source: PPC Land

The Red Iberoamericana de Protección de Datos (RIPD), the network of data protection authorities across Spain, Portugal and Latin America, has published a 29-page set of standards on how personal data rules apply to AI, PPC Land reports. The document says it was published in November 2026 but gives no day.

The central provision for commerce says that when an AI provider or processor uses a client's personal data to develop, train, evaluate or improve its own models, that use is, as a general rule, a different purpose outside the client's mandate unless there is express authorization and a legal basis. Anonymizing the data first does not change that, according to the text. Brands that plug third-party models into customer service or audience tools remain responsible for verifying the processing complies.

The standards also say inferences that let health, beliefs, ideology or sexual orientation be attributed to a person fall under the sensitive-data regime, however accurate the inference. Simply saying AI or algorithms are used does not meet the duty to inform, and public availability of data does not by itself justify AI training. For AI agents, controllers must limit autonomy, data and tools, keep action logs and provide a way to interrupt them independently of the system.

The document is guidance with no enforcement mechanism of its own and applies without prejudice to national law. PPC Land notes it does not list the authorities that approved it, and its weight will depend on whether national regulators cite it.

Read the full article at PPC Land

Our take

If you sell in Spain, Portugal or Latin America, this is how regulators there are signaling they will read your AI vendor contracts, ad segments and privacy notices.

  • Ask CRM, analytics and ad vendors in writing whether they train their own models on your customer data.
  • Audit interest segments that could stand in for health, religion or politics.
  • Watch whether national authorities start citing the standards, since the text is not binding on its own.

Was our take useful?

Key takeaways

  1. RIPD says vendor AI training on client data is a separate purpose by default
  2. Anonymizing client data first does not get vendors around the rule, per RIPD
  3. Inferred health, beliefs or orientation count as sensitive data, however accurate