PrivCom signs GPA’s Joint Statement on AI-Generated Imagery

The Office of the Privacy Commissioner for Bermuda (PrivCom) has signed the Joint Statement on AI-Generated Imagery, published today by data protection authorities across the globe and coordinated by the Global Privacy Assembly’s (GPA) International Enforcement Cooperation Working Group (IEWG). PrivCom has recently co-sponsored two AI-related resolutions at the 2025 GPA.

The Joint Statement represents the united position of 61 data protection and privacy watchdogs in response to serious concerns about artificial intelligence (AI) systems that generate realistic images and videos depicting identifiable individuals without their knowledge and consent.

AI can undoubtedly bring meaningful benefits for individuals and society, including in education as PrivCom has previously observed (see DPW 2024: teaching young people how to use ChatGPT). However, recent developments, particularly AI image and video generation integrated into widely accessible social media platforms, have enabled the creation of non-consensual intimate imagery, defamatory depictions, and other harmful content featuring real individuals. The co-signatories are especially concerned about potential harm that cyber-bullying and/or exploitation pose to children and other vulnerable groups.

The Joint Statement outlines key expectations and fundamental principles for all organisations developing and using AI content generation systems, including:

• implementing robust safeguards to prevent the misuse of personal information and generation of non-consensual intimate imagery and other harmful materials, particularly where children are depicted;

  
  

• ensuring meaningful transparency about AI system capabilities, safeguards, acceptable uses and the consequences of misuse;

• providing effective and accessible mechanisms for individuals to request the removal of harmful content involving personal information and respond rapidly to such requests; and

• addressing specific risks to children through implementing enhanced safeguards and providing clear, age-appropriate information to children, parents, guardians and educators.

  
  

The co-signatories aim to share information on their approaches to addressing these concerns, including in the areas of enforcement, policy and education and awareness.

The co-signatories are reminding all organisations developing and using generative AI systems that such systems must be developed and used in accordance with applicable laws and regulations, including data privacy legislation, such as Bermuda’s Personal Information Protection Act 2016 (PIPA). The harms arising from non-consensual generation of intimate, defamatory, or otherwise harmful content depicting real individuals are significant and call for urgent regulatory attention.

The co-signatories also highlight that the creation of non-consensual intimate imagery can constitute a criminal offence in many jurisdictions. In Bermuda, the Criminal Code Amendment (Non-Consensual Sharing of Intimate Images) Act 2021 criminalises the non-consensual distribution of intimate images. The Act addresses various offences, including observing or recording individuals in private settings without consent and distributing intimate images without permission. To learn more about some of the privacy-related concerns, read PrivCom’s blog post Non-consensual sharing of intimate images and PIPA.

What is the GPA?

The GPA is a global forum that brings together more than 130 data protection and privacy watchdogs worldwide. It seeks to provide leadership in data protection and privacy.

The Assembly has been in existence for more than four decades. It first met in 1979 and was known until 2019 as the International Conference of Data Protection and Privacy Commissioners. In September 2020, PrivCom joined the GPA as an accredited member. PrivCom hosted the 45^th GPA in Bermuda in October 2023. To find out more, read Bermuda 2023 GPA Annual Meeting: Ripples, Waves & Currents or visit 45th Annual Global Privacy Assembly Open Sessions - YouTube.