South Korea's AI Data Amendment Could Change How Personal Data Is Used for AI

Artificial intelligence development needs data. That much is obvious. The harder question is what happens when that data belongs to real people.
South Korea is now considering an amendment to its Personal Information Protection Act that could significantly change how organizations use personal information to develop and improve artificial intelligence systems. The proposal would allow certain lawfully collected personal information, including information that has not been anonymized or pseudonymized, to be used for artificial intelligence development without obtaining new consent from the individual and beyond the purpose for which the information was originally collected, but only with approval from the Personal Information Protection Commission.
That is a significant change because it moves the discussion away from the familiar question of whether an organization has consent and toward another question: under what conditions should a regulator allow personal information to be reused for artificial intelligence?
The Personal Information Protection Commission Would Have a Bigger Role
Under the proposed amendment, new provisions, Articles 28-12 through 28-15, would create a special route for using personal information in artificial intelligence development, including improving artificial intelligence systems. The proposed framework would apply where anonymization or pseudonymization is not enough, appropriate safeguards are in place, the use serves purposes such as public interest or social benefit, and the risk of unfair infringement is considered sufficiently low.
The important part is that organizations would not simply decide for themselves that their use of personal information meets those conditions. The Personal Information Protection Commission would assess the proposed use on a case-by-case basis.
That gives the regulator a much more direct role in deciding when personal information can be reused for artificial intelligence.
Why This Matters for Artificial Intelligence Training
Training an artificial intelligence system can require enormous amounts of information, and organizations developing these systems often face a practical problem: useful datasets may contain personal information.
South Korea's Personal Information Protection Commission has already acknowledged this tension. In May 2026, the Commission said it was considering special provisions for artificial intelligence and guidance on the use of pseudonymized data after discussions with the robotics industry about the practical challenges of collecting and using personal information in artificial intelligence development.
The proposed amendment takes that conversation a step further by creating a possible legal pathway for using personal information that cannot simply be anonymized or pseudonymized.
For organizations, that could make certain artificial intelligence development projects easier to pursue. For individuals, however, it raises an equally important question about how much control they should retain over information they originally provided for a different purpose.
The Interesting Part Is Not Just the Data
The most interesting part of this proposal may actually be where the decision-making power sits.
Instead of creating a broad permission for organizations to reuse personal information whenever they believe the use is beneficial, the proposed framework would require regulatory approval. The Personal Information Protection Commission would therefore become an important checkpoint between an organization's proposed artificial intelligence use and the personal information involved.
That approach fits with the Commission's broader move toward more proactive oversight as artificial intelligence becomes part of everyday products and services. The Personal Information Protection Commission has said that its existing enforcement-focused approach is no longer enough for an increasingly data-driven and artificial intelligence-enabled environment and has outlined plans to strengthen preventive and trustworthy data governance.
There Is Still a Big Question About Trust
Giving a regulator the authority to approve certain uses of personal information can create a clearer process for organizations, but it also makes regulatory judgment extremely important.
The proposal is built around conditions such as appropriate safeguards, social benefit, and a low risk of unfair infringement. Those terms matter because they determine when the exception can actually be used. The way the Personal Information Protection Commission interprets and applies those standards could therefore have a major effect on how artificial intelligence developers approach training data.
This is why the amendment is worth watching even before the legislative process is complete. It is not simply about whether artificial intelligence companies can access more data. It is about how South Korea wants to balance technological development with individual privacy when existing consent and purpose limitations do not fit neatly with artificial intelligence development.
What This Could Mean for Privacy Professionals
For privacy professionals working with artificial intelligence, this development is a useful reminder that artificial intelligence governance is becoming closely connected with traditional data protection questions.
The difficult issues are often not about artificial intelligence alone. They involve familiar privacy concepts such as lawful processing, purpose limitation, data minimization, safeguards, accountability, and the rights of individuals. What is changing is the context in which those principles have to be applied.
South Korea's proposal shows one possible approach: rather than creating a blanket permission for artificial intelligence training, the government could allow certain uses while placing the decision under regulatory supervision.
The proposal is still moving through the legislative process, so its final form and implementation should be watched closely. For now, it offers a useful example of how privacy regulators and lawmakers are trying to deal with one of the hardest questions in artificial intelligence governance: when can personal information collected for one reason legitimately be reused to build something entirely new?
Why This Matters for CIPP/A Preparation
This development is relevant to the Certified Information Privacy Professional/Asia (CIPP/A) certification because it connects artificial intelligence governance with key data protection principles in the Asian regulatory context. South Korea’s proposed amendment raises questions about purpose limitation, lawful processing, data minimization, and the reuse of personal information for new purposes.
For CIPP/A candidates, the proposal provides an example of how privacy regulators may respond to emerging technologies while balancing innovation and individual rights. It also highlights the importance of understanding the role of regulatory authorities, including when organizations may need approval before using personal information in new ways.
The amendment is still part of the legislative process, so candidates should distinguish between existing legal requirements and proposed changes. Its development shows why privacy professionals need to understand both the wording of privacy laws and how regulators apply concepts such as accountability, safeguards, and personal information protection in artificial intelligence-related activities.




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