Sicreto Labs / GDPR / Compliance pack

For AI labs' legal and procurement teams

The compliance pack: how Sicreto is designed to document every dataset

What a lab's counsel would need to approve EU workplace data, and how Sicreto plans to provide it with each licence. This describes how Sicreto works; Sicreto has not delivered data commercially yet, so no pack has been issued to a customer.

Guidance, not legal advice. Sicreto Labs is not a law firm and does not hold any GDPR certification. The documents below are being prepared and have not yet been reviewed by Spanish counsel.

Designed contents

Ten documents, each tied to a rule

  • Per-clip consent manifestEach clip or record carries a pseudonymous person ID, the consent-form version and flags such as train_ok, eval_only and non_eea_ok, so use can be limited to what each person agreed.GDPR Art 7(1) (demonstrate consent)
  • Consent form and privacy notice versionsThe exact text each person signed, in their language, with the Art 13 notice they received. Granular yes/no boxes, none pre-ticked.GDPR Art 7, 13; EDPB Guidelines 05/2020
  • Site agreement and bystander protocolCapture zones and times, excluded areas, signage, the ban on using footage to monitor workers, and confidentiality of who declined.LOPDGDD art 89; EDPB Guidelines 3/2019
  • Redaction log and raw-deletion certificateWhat was blurred or cut in each clip, who reviewed it, and when raw footage was deleted. Blurred video is still treated as personal data.GDPR Art 5(1)(c), 25; WP29 Opinion 05/2014
  • DPIA summary and record of processingThe impact assessment for the capture programme and the Art 30 record entry, shared as a summary.GDPR Art 30, 35; AEPD DPIA list
  • Roles and licence termsController-to-controller terms (or an Art 26 arrangement if purposes are set jointly), a licence rather than an assignment, field of use, bans on re-identification, biometric identification, workplace emotion recognition and resale.GDPR Art 26, 28; AI Act Art 5(1)(f)
  • Transfer documentationYour DPF listing checked and dated, or SCCs 2021 Module 1 with annexes and a transfer impact assessment. Open question flagged for counsel: SCCs where the importer is itself subject to GDPR.GDPR Art 44-46; Decision (EU) 2021/914
  • Withdrawal propagation processWithdrawal notices by pseudonymous ID; deletion from stored datasets within an agreed period and exclusion from future training, with a deletion certificate. No promise that trained models forget.GDPR Art 7(3), 17, 19
  • AI Act training-data summary inputsSource type, collection method and date range for your Art 53(1)(d) public summary, without participant identities.AI Act Art 53(1)(d); Commission template, 24 Jul 2025
  • EU representative and contact pointSicreto Labs LLC is a US company, so it needs an Art 27 EU representative. It is still to be appointed and will be named in the pack once appointed.GDPR Art 27

Drafts of several of these are available as free templates: licence key terms, data-sharing outline, transfer checklist, DPIA outline.

Limits

What the pack does not claim

  • It is not a certification, a legal opinion or a guarantee that your use is lawful. Your counsel decides.
  • Blurred video is not described as anonymous.
  • It does not promise that a trained model can forget a withdrawn person.
  • It never includes existing security or CCTV footage.