EU’s GDPR Article 7 Poses New Challenges for Businesses To Secure AI-Generated Image Data

As businesses worldwide embrace digital transformation, the European Union’s General Data Protection Regulation (GDPR), enacted in 2018, remains a cornerstone of data privacy and security.

A recent safety report highlighting the rapid advancement of artificial intelligence (AI) has renewed focus on GDPR compliance, particularly Article 7, which governs consent requirements for handling personal data, including images and videos.

With organizations increasingly leveraging AI for image generation and processing, ensuring compliance is proving to be a complex but critical task.

The Growing Importance of GDPR in Image Management

GDPR classifies any image or video containing identifiable individuals—such as employee headshots or event photos—as personal data.

Article 7 mandates that organizations obtain explicit, documented consent before collecting, using, or sharing such assets.

This requirement extends across corporate websites, social media, and marketing materials, creating unique challenges for businesses scaling their digital operations.

“Images are no longer just marketing tools ...