- Does the model vendor train on our data?
- This is a contractual question, not an architectural one, and it is the single most important thing to establish before you send a byte. Do not take a general answer from a supplier, including from us, and do not rely on what is true of a consumer product being true of the business API. Read the terms of the specific model and the specific plan you are on, and look for four things: whether inputs and outputs may be used to train or improve models, whether there is an opt-out or whether the business tier excludes it by default, how long the vendor retains what you send and for what purpose, and whether human reviewers may see it. Those four answers, in writing, are what the review wants. Where the terms cannot satisfy your constraint, that is the signal to move the model inside your own cloud rather than to negotiate the constraint.
- What about personal data inside the documents themselves?
- Assume it is there, because in operational documents it usually is, in the free-text fields nobody thinks of. There are three postures and they are not exclusive. You can exclude: keep documents and fields that carry personal data out of the index entirely, which is clean and loses whatever value they held. You can redact or pseudonymise before indexing, replacing identifiers with tokens — this reduces exposure, and be clear-eyed that redaction over free text is imperfect and that a person is often re-identifiable from the surrounding detail. Or you can permit it and control it, by keeping the crossing narrow, applying the user's own permissions at retrieval, treating the audit log as sensitive because it now contains the same text, and pinning residency. Which posture is required for your data is a decision for your DPO. What we can do is build to whichever they choose and show them exactly where the data goes under it.
- Can we use this under GDPR, or the EU AI Act?
- We will not tell you that an architecture is compliant, because compliance is a determination about your organisation, your purpose and your data, and it is made by your counsel or your data protection officer. What we can do is build a system that is possible to assess, which is where most projects fail long before they reach a lawyer. Broadly, data protection regimes such as the GDPR ask about lawful basis, purpose limitation, minimisation, transfers outside the region, retention, and the rights of the individual including deletion — and every one of those is easier to answer when the boundary is drawn, retrieval is minimised, residency is pinned and deletion propagates. The EU AI Act, again broadly, places obligations that vary with the risk category of the use, with heavier duties for high-risk applications around documentation, human oversight and record-keeping. Our part is the record-keeping, the oversight points and the documentation of what the system does. Your counsel's part is the categorisation and the legal conclusion, and we would rather hand them a clear architecture than an opinion.
- What about India's DPDP Act?
- The same division of labour applies, and the same warning against taking legal conclusions from a supplier. India's Digital Personal Data Protection Act, 2023 sets out obligations for organisations handling the personal data of individuals in India, with themes a security review will recognise: a basis for processing that generally rests on notice and consent, purpose limitation, obligations around accuracy and security, breach notification, and the rights of the individual including correction and erasure. Rules and enforcement detail have continued to develop, so the current position should be checked with counsel rather than assumed from any summary — including this one. For an AI system the practical consequences are familiar: know what personal data is in the index, be able to delete it from the index and not only from the source, be able to say where it is processed, and keep the record that shows both. If you operate across India and the EU, build to the stricter constraint rather than maintaining two architectures.
- Who can see the logs?
- Fewer people than can see the application, and the number should be written down before launch. The audit trail contains the questions people asked and the passages retrieved to answer them, which makes it as sensitive as the documents it draws from and sometimes more revealing, because a question discloses intent. So it gets its own access rules, and reading it is itself logged. In practice we separate two things that are usually conflated: an operational log of latency, errors and token counts, which engineers need routinely and which should carry no content, and the content-bearing audit record, which is restricted to named roles — typically security, compliance and a small number of system owners — and read on cause rather than by habit. Where an engineer needs content to debug a specific failure, that is an access request with a reason attached, not a default. Who those named roles are is your decision, and it belongs in the review pack rather than in a configuration file discovered later.