Do LLMs ‘store’ personal data? This is asking the wrong question 

Morrison Foerster Senior Counsel Lokke Moerel and Of Counsel Marijn Storm explored the implications of the Hamburg Commissioner for Data Protection and Freedom of Information’s stance on large language models as a personal data storage conduit. The two argue in DPA’s stances do not follow prior rulings from the Court of Justice of the European Union and the European Data Protection Board, noting the rulings would absolve chatbot providers of any inaccurate output claims.
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