Joint Statement on Privacy Risks of AI-Generated Imagery (2026-02-23)

Summary

This is a joint statement issued by Guernsey's Office of the Data Protection Authority (ODPA) together with 60 other data protection authorities worldwide, addressing privacy risks arising from AI-generated imagery, including deepfakes and non-consensual intimate imagery. It sets out shared expectations for organisations that develop or use AI content generation systems, with particular concern for harms to children.

• Safeguards: Implement robust safeguards to prevent misuse of personal information and generation of non-consensual intimate imagery or other harmful material, especially involving children.
• Transparency: Ensure meaningful transparency about AI system capabilities, safeguards, acceptable uses and consequences of misuse.
• Removal mechanisms: Provide effective, accessible mechanisms for individuals to request removal of harmful content involving their personal information and respond rapidly to such requests.
• Child protection: Address specific risks to children through enhanced safeguards and clear, age-appropriate information for children, parents, guardians and educators.

The Statement was coordinated by the Global Privacy Assembly's International Enforcement Cooperation Working Group, for which Guernsey's ODPA acts as secretariat and co-chair. The ODPA has also joined Jersey and the Isle of Man in issuing a separate Crown Dependencies Data Protection Advisory on Generative AI Image creation aimed at helping individuals protect themselves from misuse of AI-generated imagery.

Key obligations

• Organisations developing or using AI content generation systems are expected to implement safeguards preventing misuse of personal data and generation of non-consensual intimate or harmful imagery
• Organisations should provide transparency about AI system capabilities, safeguards, acceptable uses and consequences of misuse
• Organisations should provide accessible mechanisms for individuals to request removal of harmful AI-generated content and respond rapidly to such requests
• Organisations should implement enhanced safeguards and provide age-appropriate information to protect children from AI-generated imagery risks

Applies to

organisations developing AI content generation systems, organisations using AI content generation systems