MARCH 16, 2026

Joint statement by the AAPI and international authorities on privacy and AI-generated imagery

CIRCULARS

Data Privacy & Data Protection – Cybersecurity Department Report | Joint statement by the AAPI and international authorities on privacy and AI-generated imagery.

Dear All,

On March 12, 2026, the official website of the National Government published the news that, within the framework of the International Enforcement Cooperation Working Group of the Global Privacy Assembly (GPA), the Agency for Access to Public Information (“AAPI“), together with governing bodies from Albania, Germany, Andorra, Australia, the United Arab Emirates, Slovenia, Spain, Belgium, Bermuda, Brazil, Bulgaria, Burkina Faso, Canada, Cape Verde, Colombia, Croatia, Cyprus, Ecuador, the Philippines, France, Ghana, Gibraltar, Guernsey, China, Iceland, the Isle of Man, Israel, Italy, Jersey, Kenya, Kosovo, Malta, Mauritius, Mexico, Monaco, New Zealand, Nigeria, Norway, the Netherlands, Peru, Portugal, the United Kingdom, the Republic of Korea, Singapore, Switzerland, and Uruguay (the “Co-signatories“), signed a joint statement regarding the protection of privacy against images and videos generated by artificial intelligence (the “Statement“) (available here).

The purpose of the Statement is to respond to serious concerns about systems that generate realistic images and videos of identifiable individuals without their knowledge or consent, which has enabled the creation of non-consensual intimate imagery, defamatory depictions, and other harmful content. The Co-signatories also express concern about potential harm to children and other vulnerable groups, such as cyberbullying and/or exploitation.

The Statement provides that the following fundamental principles should guide all organizations that develop and use AI-powered content generation systems:

-Implement robust safeguards to prevent the misuse of personal information and the generation of non-consensual intimate imagery and other harmful materials, particularly where children are depicted

-Ensure meaningful transparency about AI system capabilities, safeguards, acceptable uses and the consequences of misuse.

-Provide effective and accessible mechanisms for individuals to request the removal of harmful content involving personal information and respond rapidly to such requests.

-Address specific risks to children through implementing enhanced safeguards and providing clear, age-appropriate information to children, parents, guardians and educators.

-The Co-signatories aim to share information about their approaches to addressing these concerns, which may include enforcement actions, policies, and education. They also call on organizations to proactively engage with regulators, implement strong safeguards from the outset, and ensure that technological advancement does not come at the expense of privacy, dignity, safety, and other fundamental rights, especially those of the most vulnerable members of global society.

We remain at your disposal for any further information you may require.

Yours sincerely

Emilio Beccar Varela

Florencia Rosati

Andrea Sánchez Vicentini