Danish watchdog rejects web notice for AI trained on 3,000 student aid files

Denmark's data protection authority, Datatilsynet, has told a government agency it may train an AI system on about 3,000 historical applications for the SU disability supplement, the student grant extra for people with disabilities. It also ruled that a notice on the agency's website would not be enough to inform the applicants whose files are used. The opinion is dated June 12, 2024 and filed under journal number 2024-212-0371.

The request came from the Danish Agency for Higher Education and Science, which planned to build the tool with cBrain, a Danish software company. The past applicants whose cases make up the training data are the people who would need to be told.

The system has a narrow purpose. It would check whether an incoming application for the disability supplement comes with sufficient documentation, judging both how much material is attached and what type. If the system decides the documentation falls short, the case is placed for manual screening and the applicant is asked to provide more. As described, the tool flags incomplete files and does not decide on the grant itself.

The ruling matters because it shows how Danish authorities are applying data protection rules when public bodies reuse past case files to train AI. Training can go ahead, but the agency cannot rely on a general website notice to meet its duty to inform people whose applications were used. The source text available here does not set out what form of notification Datatilsynet expects instead.