On 27 June 2024, the EDPB launched a project under the Support Pool of Experts program to assess data protection risks associated with AI-powered Optical Character Recognition (OCR). This project, led by external expert Isabel Barbera and completed in September 2023, identifies and evaluates various privacy and security risks posed by OCR technology.
Background on OCR Technology
- OCR converts images or scanned documents into machine-readable text.
- Common applications include digitizing documents, license plate recognition, consumer behavior analysis, assistive technologies, and medical documentation.
Identified Risks
- Processing Sensitive Data: OCR systems often handle sensitive information, including health data, financial records, and legal documents. Inadequate processing can lead to significant privacy violations.
- Large Scale Processing: High volumes of data increase the risk of breaches. Proper safeguards must be implemented to protect such data.
- Vulnerable Individuals: Processing data of children, elderly, or other vulnerable groups requires stringent protections to avoid potential exploitation.
- Low Data Quality: Poor input data quality can result in inaccuracies, affecting the reliability of the OCR output and leading to potential misuse of incorrect information.
- Insufficient Security Measures: Lack of adequate security can lead to data breaches, unlawful data transfers, and other privacy infringements. Ensuring data encryption, access controls, and secure transmission is crucial.
- Unlawful Data Storage: Storing data longer than necessary or without appropriate safeguards contravenes GDPR principles. Clear data retention policies are essential to comply with legal requirements.
- Unlawful Data Transfer: Transferring data to jurisdictions without adequate protections poses significant risks. Proper assessments and safeguards are necessary for cross-border data flows.
Mitigation Strategies
- Implement Robust Safeguards: Ensure data encryption, access controls, and secure data transmission to prevent breaches.
- Regular Risk Assessments: Continuously monitor and assess risks to identify and mitigate potential threats.
- Data Minimization: Only process the data necessary for the specific OCR task, reducing the potential for misuse.
- Quality Assurance: Regularly verify the accuracy and quality of input data to ensure reliable OCR output.
- Compliance with GDPR: Adhere to GDPR requirements, including data minimization, lawful processing, and ensuring the rights to rectification and erasure.
The report emphasizes the importance of stringent safeguards and regulatory compliance to mitigate data protection risks associated with OCR technology. Implementing these measures can help organizations leverage OCR while protecting individual privacy rights.
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