CASE STUDY
A global marketing agency is adapting a large language model ("LLM") to generate content for an upcoming marketing campaign for a client's new product: a hard hat designed for construction workers of any gender to better protect them from head injuries.
The marketing agency is accessing the LLM through an application programming interface ("API") developed by a third-party technology company. They want to generate text to be used for targeted advertising communications that highlight the benefits of the hard hat to potential purchasers. Both the marketing agency and the technology company have taken reasonable steps to address Al governance.
The marketing company has:
* Entered into a contract with the technology company with suitable representations and warranties.
* Completed an impact assessment on the LLM for this intended use.
* Built technical guidance on how to measure and mitigate bias in the LLM.
* Enabled technical aspects of transparency, explainability, robustness and privacy.
* Followed applicable regulatory requirements.
* Created specific legal statements and disclosures regarding the use of the Al on its client's advertising.
The technology company has:
* Provided guidance and resources to developers to address environmental concerns.
* Build technical guidance on how to measure and mitigate bias in the LLM.
* Provided tools and resources to measure bias specific to the LLM.
* Enabled technical aspects of transparency, explainability, robustness and privacy.
* Mapped and mitigated potential societal harms and large-scale impacts.
* Followed applicable regulatory requirements and industry standards.
* Created specific legal statements and disclosures regarding the LLM. including with respect to IP and rights to data.
Which stakeholder is responsible for the lawful collection of data used to train the foundational AI model?
The correct answer isB -- The tech company. The party thatdevelops and trains the foundational modelis responsible for ensuring thelawful collection of training data.
From the AIGP ILT Guide -- Foundational Models & Data Governance:
''Responsibility for the lawfulness of data collection typically lies with the party that trains the model---usually the provider or developer of the foundational model.''
AI Governance in Practice Report 2025 confirms:
''General Purpose AI providers are required to ensure that training data is lawfully acquired, including compliance with intellectual property and privacy requirements.''
The marketing agency is only auserordownstream integrator, not responsible for original data collection.