An AI-assisted Approach for Checking the Completeness of Privacy Policies Against GDPR
Bibliographic record
Abstract
Privacy policies are critical for helping individuals make informed decisions about their personal data. In Europe, privacy policies are subject to compliance with the General Data Protection Regulation (GDPR). If done entirely manually, checking whether a given privacy policy complies with GDPR is both time-consuming and error-prone. Automated support for this task is thus advantageous. At the moment, there is an evident lack of such support on the market. In this paper, we tackle an important dimension of GDPR compliance checking for privacy policies. Specifically, we provide automated support for checking whether the content of a given privacy policy is complete according to the provisions stipulated by GDPR. To do so, we present: (1) a conceptual model to characterize the information content envisaged by GDPR for privacy policies, (2) an AI-assisted approach for classifying the information content in GDPR privacy policies and subsequently checking how well the classified content meets the completeness criteria of interest; and (3) an evaluation of our approach through a case study over 24 unseen privacy policies. For classification, we leverage a combination of Natural Language Processing and supervised Machine Learning. Our experimental material is comprised of 234 real privacy policies from the fund industry. Our empirical results indicate that our approach detected 45 of the total of 47 incompleteness issues in the 24 privacy policies it was applied to. Over these policies, the approach had eight false positives. The approach thus has a precision of 85% and recall of 96% over our case study.
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How this classification was reachedexpand
Full frame machine prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. The Gemma side is a direct model label for every work in the frame, read from the title-only record. The Codex side is a classifier learned from the 10,348 direct Codex labels and calibrated to design-weighted sample rates; fields without enough sample support carry no Codex call. Candidate is the union of the two sides; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels.
Distilled classifier scores by category (both heads)
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.019 | 0.093 |
| Meta-epidemiology (narrow) | 0.001 | 0.001 |
| Meta-epidemiology (broad) | 0.001 | 0.002 |
| Bibliometrics | 0.013 | 0.004 |
| Science and technology studies | 0.002 | 0.003 |
| Scholarly communication | 0.006 | 0.010 |
| Open science | 0.003 | 0.005 |
| Research integrity | 0.003 | 0.005 |
| Insufficient payload (model declined to judge) | 0.003 | 0.001 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one source (direct Gemma or distilled Codex), not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".