The AI right to unlearn: Reconciling human rights with generative systems

The Cirrus Institute for AI and Data Governance's Nicoletta Kolpakov explores the growing field of research known as machine unlearning: methods that aim to make a large language model forget specific data without retraining it from scratch.

Contributors:
Nicoletta Kolpakov
Director of law and policy
Cirrus Institute for AI and Data Governance
The right to be forgotten, codified in Article 17 of the EU General Data Protection Regulation, was originally conceived as a privacy safeguard. But its deeper function lies in self-determination: the individual's authority to decide when their past ceases to define their present.
Generative artificial intelligence undermines that autonomy by making "memory" probabilistic. A large language model does not store text as static records but as distributed patterns of statistical association. To remove one person's data requires altering billions of interdependent parameters, effectively reconfiguring the model's identity. Unlike a spreadsheet, an AI cannot simply "delete row 42."
The technical frontier of 'unlearning'
This challenge has spawned a growing field of research known as machine unlearning: methods that aim to make a model forget specific data without retraining it from scratch.
In principle, unlearning offers a bridge between human rights law and technical feasibility. In practice, it is fraught with trade-offs. Retraining from zero after every deletion request would guarantee compliance, but at astronomical computational cost.
More efficient methods can approximate forgetting but often leave residual traces, such as: gradient subtraction — unlearning without retraining; influence-function updates — which measure how each data input influences prediction patterns over a specific testing point; or sharded retraining — which splits datasets into smaller "shards."
The problem is measurement. How does one prove that forgetting has occurred? Recent efforts like the NeurIPS 2023 Machine Unlearning Challenge have sought to create benchmarks for evaluating unlearning effectiveness, from adversarial testing to model behavior comparisons. However, there is still no consensus on what constitutes "successful" erasure in probabilistic systems.
New research: Source-free unlearning
Contributors:
Nicoletta Kolpakov
Director of law and policy
Cirrus Institute for AI and Data Governance