AI Video Translation & Data Protection – What Really Matters in the EU

Why video translation is a data protection issue

Videos often contain personal data, such as:

• A person’s voice (a biometric identifier)
  
• Recognisable faces or individuals
  
• Spoken content revealing roles, opinions, or confidential information
  
  

Whether it’s an internal training video or a public-facing brand message – as soon as identifiable people are involved, the General Data Protection Regulation (GDPR) applies.

This makes companies responsible for ensuring any third-party AI provider processes the content lawfully, securely, and transparently.

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What the GDPR requires

Under the GDPR, any processing of personal data must meet strict requirements. These include:

Data Processing Agreement

If a third-party provider (like Dubly) processes video data, a Data Processing Agreement (DPA) under Article 28 GDPR is mandatory.

Data Subject Rights

Data subjects (e.g., employees, customers, partners) have the right to access, correction, and deletion of their personal data. Companies must ensure this is technically and contractually possible.

Purpose Limitation & Data Minimisation

Only the data strictly necessary for the translation task may be used – and only for the specified purpose.

Security & Technical Safeguards

Providers must implement appropriate Technical and Organisational Measures (TOMs), such as encryption, access control, and audit logging.

Deletion & Retention Rules

Video and audio data must be deleted promptly once it’s no longer needed.

International Transfers

If non-EU subprocessors (e.g. in the US) are involved, EU Standard Contractual Clauses (SCCs) must be in place to ensure lawful processing.

The problem with many AI platforms

Many AI video translation tools are built for speed and convenience – but neglect core data protection principles. Common issues include:

• Processing data on US-based servers without safeguards
  
• No DPA available or incomplete contracts
  
• Reuse of user data for training general AI models
  
• Lack of transparency on data retention or subprocessors
  
• No way to fulfil access or deletion requests
  
• No real control over security standards
  
  

In short: what seems like a smart tech shortcut can become a legal and reputational liability – especially for organisations in the EU.

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Your GDPR compliance checklist

Before choosing an AI video translation provider, check for the following:

• Is a Data Processing Agreement (DPA) under Article 28 available?
  
• Is data stored exclusively in the EU – and only processed under SCCs where necessary?
  
• Are your files excluded from any AI model training?
  
• Are technical and organisational safeguards (TOMs) properly documented?
  
• Are deletion and retention policies clearly defined and implemented?
  
• Can the provider support full compliance with data subject rights (access, erasure, etc.)?
  
• Can NDAs or custom confidentiality agreements be signed if needed?
  
  

If the answer to any of these is unclear or negative – proceed with caution.

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