DATA & MODEL PROVENANCE
Describe the provenance of your training data and the rights under which it is used.
Current as of July 2026.
A model answer
For each model we use or fine-tune, we record the categories of training data, their source, the lawful basis or licence under which they are used, and any restrictions attached. Where we build on a third-party foundation model, we record the provider, the model version, and the transparency documentation the provider publishes. Customer data is not used to train shared models. Data-governance records are maintained per system and available under NDA.
Evidence a buyer expects
A data-governance record per system: categories, source, lawful basis, retention, and the explicit position on customer data. The "we do not train on customer data" line will be checked against your contract and your DPA.
Why weak answers fail
Vagueness here reads as evasion, because it usually is. "Publicly available data" is not a rights position. And any inconsistency between this answer, your privacy policy and your contract will be found — reviewers read all three side by side.
What Hael produces
Hael's Data Governance Record (EU AI Act Article 10, GDPR, ISO/IEC 42001 Annex A.7): provenance, lawful basis, quality, retention — sealed and cited.
Related questions
Current as of July 2026. General information, not legal advice.
Keep reading
More from the answer library.
DATA & MODEL PROVENANCE
Do you maintain model cards, and do they disclose known limitations?
Read answer →
SUPPLY CHAIN & INCIDENTSList your AI sub-processors and describe how you assess them.
Read answer →
CERTIFICATION & FRAMEWORKSHas your AI system been classified under the EU AI Act, and what obligations apply?
Read answer →