At Rise of AI 2018 in Berlin, Labhesh Patel, CTO and chief scientist at Jumio, explains how the EU's General Data Protection Regulation, taking effect a week after the talk, will reshape machine learning workflows. He describes Jumio's business verifying identities online by comparing a selfie to an ID document using machine learning and human review, which puts the company squarely under GDPR because it handles images, names, addresses and birth dates. He outlines the regulation's two fine tiers, up to 20 million euros or 4% of global revenue, and explains that GDPR now makes data processors, not just controllers, liable for breaches. Patel lays out practical steps toward compliance: encryption, human review of automated decisions under GDPR's right to explanation, configurable data retention, and 72-hour breach notification. He introduces 'compliant machine learning', building privacy and security into every stage of a pipeline, from data acquisition and tagging to training, deployment and evaluation, and explains why data from different customers cannot be commingled to train one shared model under the regulation's data minimization principle.
Key takeaways
- Labhesh Patel argues GDPR applies to any company processing EU citizens' data, regardless of where its servers are located.
- GDPR fines reach 20 million euros or 4% of global revenue, and now make data processors, not just controllers, liable.
- GDPR's recital 71 lets users contest fully automated decisions, requiring machine learning systems to give human-interpretable explanations.
- Patel calls for 'compliant machine learning' that builds privacy and security into every stage of the ML pipeline.
- Data minimization rules prevent a processor from training one shared model on multiple controllers' customer data.
Detailed notes
Jumio's identity verification business and why it sits inside GDPR
Patel describes Jumio's two products: authenticating a user's ID document and verifying that the person present in a transaction matches that ID, using machine learning, facial recognition and human review. Because this involves images, names, addresses and birth dates, GDPR applies to Jumio and to any company handling EU citizens' data regardless of where its servers are based, once the regulation takes effect on 25 May.
Fines, controllers and processors
He explains GDPR's two fine tiers: a lower tier of 10 million euros or 2% of global annual revenue for failures like inadequate data security design, and an upper tier of 20 million euros or 4% for specific infringements such as shipping personal data to another country without safeguards. He notes the UK's Information Commissioner's Office hired more than 200 people to prepare for enforcement, and that GDPR newly makes processors, not only controllers, liable for penalties, so the two now have to manage compliance together.
Practical first steps toward compliance
Patel lists concrete steps: baseline data encryption, for example using PCI DSS as a security standard; human review of automated decisions, since GDPR's recital 71 lets a person contest a purely automated outcome such as a denied mortgage application and requires a human-interpretable explanation; configurable data retention so a system can delete a user's data on request; and breach notification, since GDPR's definition of a personal data breach is broader than usual and requires notifying authorities and affected users within 72 hours.
Compliant machine learning across the pipeline
Because GDPR does not mention machine learning directly, Patel reads its right to erasure (Article 17) and right to explanation (recital 71) as requiring 'compliant machine learning': building privacy and security into every stage, from data acquisition, tagging and training to deployment and evaluation, keeping workflows interpretable and ensuring a user's data and its residual influence on a model can be removed on request.
Why customer data cannot be commingled
He explains GDPR's data minimization principle prevents a processor from training one shared model on data from multiple controllers' customers, since a user who consented to improve controller A's product cannot have that data used to improve controller B's product. Human-derived insights, such as a data scientist manually noticing an attribute and coding it into a second model, can be transferred, but a trained model itself cannot, which multiplies the engineering work needed per customer.
Quotes
GDPR is here now, and I think there is going to be a mad scramble to get compliant.
Labhesh Patel
My personal data should not be lingering around in your servers for longer than it is absolutely necessary.
Labhesh Patel
Questions answered in this talk
Does GDPR apply to companies outside the EU?
According to Labhesh Patel at Rise of AI 2018, GDPR applies to any company that processes EU citizens' personal data, even if its servers are based in North America, once the regulation took effect on 25 May 2018.
What are GDPR's fine levels?
Patel explains GDPR has two fine tiers: up to 10 million euros or 2% of global annual revenue for security and design failures, and up to 20 million euros or 4% for specific data protection infringements.
How does GDPR affect machine learning pipelines?
Patel says GDPR requires 'compliant machine learning', building privacy and security into data acquisition, tagging, training, deployment and evaluation, since a user's right to erasure and right to explanation must be honored at every stage.