At the end of 2024 the Italian Data Protection Authority issued a 15 million euro fine in the first generative AI-related case brought under GDPR. According to Garante (the Italian authority), OpenAI trained ChatGPT with users’ personal data without first identifying a proper legal basis for the activity, as required under GDPR. The Order also alleges that OpenAI failed to notify Garante about a data breach the company experienced in March 2023. Additionally, the Order states that OpenAI did not provide proper age verification mechanisms for users under age 13.