This is the third consultation response that we have published in 2024 and it focusses on generative artificial intelligence (“GenAI”) and its compliance with the accuracy principle. The accuracy principle gets very little attention in the world of data protection. It is often overshadowed by other principles such as transparency or fairness or security. But the principle of accuracy is just as important as the others. In its simplest terms, this principle requires that data is not incorrect or misleading about individuals. A database that described me as a Manchester City fan would be factually inaccurate and breach this principle (I am, of course, a Manchester United fan). The principle of accuracy really comes to life in the compliance debate connected to GenAI systems. It sits at the heart of the issues that GenAI creates. This is because GenAI is a general purpose tool and can be used (or misused) to create or manipulate data about people. It can also hallucinate because of its programming, choosing to answer a question with made-up information rather than suggest that it has no accurate answer to offer the user. Finally, the accuracy principle is one side of the accuracy/purpose coin, meaning that it is quite hard for an organisation to state that its data use is accurate if it is not first clear about the purpose for which it is processing data. All of this leads to the consultation response that this group of amazing contributors has produced. Each one has sacrificed time, resource and energy to help contribute to the ICO’s thinking on this critical topic. They are the brilliant, brave intellectual explorers of this niche world of data protection. Their combined thoughts in this excellent document help to show how GenAI developers and users can comply with the accuracy principle in a meaningful way and also helps to point the ICO towards the line of right and wrong. I hope you enjoy reading this response. We really enjoyed making it! Kind regards Matthew