Right to be Forgotten in the Era of Large Language Models: Implications, Challenges, and Solutions

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The Right to be Forgotten (RTBF) was first established as the result of the ruling of Google Spain SL, Google Inc. v AEPD, Mario Costeja González, and was later included as the Right to Erasure under the General Data Protection Regulation (GDPR) of European Union to allow individuals the right to request personal data be deleted by organizations. Specifically for search engines, individuals can send requests to organizations to exclude their information from the query results. It was a significant emergent right as the result of the evolution of technology. With the recent development of Large Language Models (LLMs) and their use in chatbots, LLM-enabled software systems have become popular. But they are not excluded from the RTBF. Compared with the indexing approach used by search engines, LLMs store, and process information in a completely different way. This poses new challenges for compliance with the RTBF. In this paper, we explore these challenges and provide our insights on how to implement technical solutions for the RTBF, including the use of differential privacy, machine unlearning, model editing, and prompt engineering. With the rapid advancement of AI and the increasing need of regulating this powerful technology, learning from the case of RTBF can provide valuable lessons for technical practitioners, legal experts, organizations, and authorities.


Ryan Watkins