Discussion on Machine Learning and Data Subject Rights at ULD

Meeting at partner ULD in Kiel, Germany, on November 14, 2025, the TRUMAN project members ULD and KAU organized a joint workshop where they discussed in depth the different conditions of data subject rights in the scope of artificial intelligence and machine learning models. The target was to lay down a roadmap for future ways on how to deal with data subject requests under the GDPR (like right of access, right to rectification, right to ‘be forgotten’) in the context of trained ML models like Large Language Models (LLMs). Apart from input (the ‘prompt’) and output (the ‘inference result’), questions on the status of the model itself as a data object were discussed in detail, based on a presentation by Prof. Meiko Jensen (Karlstad University) on the topic of “Machine Learning und Betroffenenrechte” (“Machine Learning and Data Subject Rights”).