Sensitive Data Exposure in Third Party or AI Integrations (beyond DPA)

Issue

Sensitive data exposure in third party or AI integrations beyond the scope of the data processing agreement.

Impacted Frameworks and Reasons

Article 5 requires lawful, fair, and purpose limited processing with data minimization and integrity. Exposing data to AI or external services without a defined purpose breaks these principles.
Article 28 requires binding processor agreements. Ungoverned third party or AI integrations violate processor oversight obligations.

CCPA and CPRA

Organizations must disclose all sharing of personal data.
Untracked or shadow integrations may qualify as unauthorized sharing or selling without proper notice or opt out options.

HIPAA

PHI may only be shared with approved business associates under a Business Associate Agreement.
Sending PHI to unapproved AI or third party services is considered unauthorized disclosure.

PCI

Cardholder data must remain protected within a controlled environment.
Any processing or transmission by unapproved services violates PCI scope and control requirements.

GLBA

Financial institutions must safeguard customer financial data.
Exposure to third party or AI systems without controls represents a failure to safeguard sensitive financial data.

PIPEDA

Requires meaningful consent for the collection, use, and disclosure of personal data.
Shadow data flows break the ability to prove informed consent and authorized disclosure.

APPI

Requires clear purpose specification and limits on sharing.
Uncontrolled integrations violate purpose limitation and disclosure rules.

NIST 800 53

Requires monitoring, auditing, access control, and supply chain oversight.
Data flowing to unmonitored integrations compromises auditability and control enforcement.

ISO IEC 29100

Requires transparency, accountability, and documented processing purposes.
Untracked third party or AI interactions undermine transparency and accountability.

KSA PDPL

Requires lawful basis and consent for processing and cross border transfers.
Sending data to uncontrolled integrations risks unlawful disclosure or transfer.

UAE PDPL

Processing must remain aligned with the stated purpose.
Shadow data flows constitute processing beyond the approved purpose.

Qatar PDPPL

Requires safeguards to prevent unauthorized disclosures and lawful transfer conditions.
Third party or AI integrations without review weaken required safeguards.

Verify that any shared data aligns with the sensitive data types and purposes defined in your privacy notice and data processing agreement. Review data that flows to external SDKs, APIs, and AI services. Restrict or remove sharing that is not contractually governed or necessary for the stated processing purpose. Document permitted data flows and enforce them in both development and runtime environments.

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