[{"data":1,"prerenderedAt":391},["ShallowReactive",2],{"blog-article-en-gdpr-ai-act-before-ai-agents-production":3,"blog-related-en-gdpr-ai-act-before-ai-agents-production":174},{"_path":4,"_dir":5,"_draft":6,"_partial":6,"_locale":7,"title":8,"description":9,"locale":7,"translationSlug":10,"date":11,"image":12,"author":13,"tags":16,"body":19,"_type":168,"_id":169,"_source":170,"_file":171,"_stem":172,"_extension":173},"/blog/gdpr-ai-act-before-ai-agents-production","blog",false,"en","GDPR and the AI Act: What to Check Before Putting an AI Agent in Production","What the GDPR and the AI Act actually require from a company using AI agents, the five points that cover most cases, and the mistake that costs the most.","rgpd-ai-act-agentes-ia-producao","2026-08-02","/images/blog/agentes-ia-empresariais-suporte-b2b.jpg",{"name":14,"role":15},"Pedro Santos","Principal Software Architect",[17,18],"Compliance","AI Agents",{"type":20,"children":21,"toc":159},"root",[22,30,37,50,61,67,72,127,133,138,143,149,154],{"type":23,"tag":24,"props":25,"children":26},"element","p",{},[27],{"type":28,"value":29},"text","It is the first serious objection in any conversation about AI in the European\nUnion, and rightly so. It is worth separating real obligation from noise.",{"type":23,"tag":31,"props":32,"children":34},"h2",{"id":33},"the-two-rules-that-apply",[35],{"type":28,"value":36},"The two rules that apply",{"type":23,"tag":24,"props":38,"children":39},{},[40,42,48],{"type":28,"value":41},"The ",{"type":23,"tag":43,"props":44,"children":45},"strong",{},[46],{"type":28,"value":47},"GDPR",{"type":28,"value":49}," applies as soon as the system processes personal data, which in\npractice is almost always: client names, emails, contact history. None of that\nchanges because AI is involved. What changes is that there is one more place the\ndata passes through, and therefore one more place to document.",{"type":23,"tag":24,"props":51,"children":52},{},[53,54,59],{"type":28,"value":41},{"type":23,"tag":43,"props":55,"children":56},{},[57],{"type":28,"value":58},"AI Act",{"type":28,"value":60}," is the European regulation specific to artificial intelligence,\napplied in phases. It classifies systems by risk and imposes obligations\nproportional to that risk. Most enterprise cases (internal assistants, back office\nautomation, customer support) fall under limited or minimal risk, where the main\nobligations are about transparency.",{"type":23,"tag":31,"props":62,"children":64},{"id":63},"what-this-requires-in-practice",[65],{"type":28,"value":66},"What this requires in practice",{"type":23,"tag":24,"props":68,"children":69},{},[70],{"type":28,"value":71},"For most enterprise projects, the essentials come down to five points:",{"type":23,"tag":73,"props":74,"children":75},"ol",{},[76,87,97,107,117],{"type":23,"tag":77,"props":78,"children":79},"li",{},[80,85],{"type":23,"tag":43,"props":81,"children":82},{},[83],{"type":28,"value":84},"Say that it is AI.",{"type":28,"value":86}," When a customer talks to an automated assistant, it must\nbe clear it is not a person. No heavy legal notice is needed; it just has to be\nobvious.",{"type":23,"tag":77,"props":88,"children":89},{},[90,95],{"type":23,"tag":43,"props":91,"children":92},{},[93],{"type":28,"value":94},"Know where the data lives.",{"type":28,"value":96}," Hosting in the European Union answers most of\nthe hard questions about international transfers.",{"type":23,"tag":77,"props":98,"children":99},{},[100,105],{"type":23,"tag":43,"props":101,"children":102},{},[103],{"type":28,"value":104},"Do not let the data train public models.",{"type":28,"value":106}," This must be written into the\ncontract with the model provider, not merely assumed.",{"type":23,"tag":77,"props":108,"children":109},{},[110,115],{"type":23,"tag":43,"props":111,"children":112},{},[113],{"type":28,"value":114},"Log what the system does.",{"type":28,"value":116}," Who consulted what, which decisions were\nautomatic and which had human approval.",{"type":23,"tag":77,"props":118,"children":119},{},[120,125],{"type":23,"tag":43,"props":121,"children":122},{},[123],{"type":28,"value":124},"Keep a person in the loop",{"type":28,"value":126}," for decisions with significant impact on people,\nsuch as candidate screening or credit decisions. In those cases the risk\nclassification rises and so do the obligations.",{"type":23,"tag":31,"props":128,"children":130},{"id":129},"the-common-mistake",[131],{"type":28,"value":132},"The common mistake",{"type":23,"tag":24,"props":134,"children":135},{},[136],{"type":28,"value":137},"The most frequent mistake is not regulatory, it is procedural: getting the system\nworking first and dealing with compliance afterwards. It always costs more,\nbecause it means redoing architectural decisions that are already in production.",{"type":23,"tag":24,"props":139,"children":140},{},[141],{"type":28,"value":142},"The reverse costs little. Defining at design time what information each agent may\nread, what it may execute alone and where the log lives is two or three sessions\nof work, not a separate project.",{"type":23,"tag":31,"props":144,"children":146},{"id":145},"what-we-do-by-default",[147],{"type":28,"value":148},"What we do by default",{"type":23,"tag":24,"props":150,"children":151},{},[152],{"type":28,"value":153},"In the systems we build, infrastructure stays in the European Union, in accounts\nthe client company controls, data does not feed public models, permissions are\ndefined by profile and every answer cites its source. Actions with real impact\nonly run unsupervised if the client explicitly allows it.",{"type":23,"tag":24,"props":155,"children":156},{},[157],{"type":28,"value":158},"We are not legal advisers and we do not give legal opinions. 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