19 June 2024
Snap My AI decision
The ICO has concluded its investigation into Snap’s approach to assessing the data protection risks of its “My AI” chatbot. Snap launched “My AI” for its premium Snapchat+ subscribers on 27 February 2023, before it was subsequently made available to all Snapchat users on 19 April 2023. In June 2023, the ICO opened an investigation into “My AI” following concerns that Snap had not met its legal obligation to adequately assess the data protection risks posed by the new chatbot.The investigation led to the ICO issuing a Preliminary Enforcement Notice to Snap on 6 October 2023 for alleged breaches of Articles 35 and 36 UK GDPR.
The investigation resulted in Snap carrying out a revised data protection impact assessment in relation to the data protection risks posed by “My AI”, which the ICO is satisfied now complies with the requirements of Article 35 UK GDPR. Following careful consideration of the representations provided by Snap in response to the Preliminary Enforcement Notice, the ICO is also satisfied that Snap did not infringe Article 36 UK GDPR in not consulting the Commissioner prior to launching the “My AI” chatbot.