The provided sources emphasize the importance of privacy policies, especially when operating a business and utilizing AI tools, but they do not contain a template or specific guidance for generating a privacy policy for a company like "Little Grass Shack Coaching."
However, the sources do highlight several key considerations and concerns regarding data privacy and security in the context of AI and Custom GPTs, which would be crucial for any company to address in its privacy policy:
Data Usage and Training by AI Providers
OpenAI, the creator of ChatGPT and Custom GPTs, reviews and uses conversations with its chatbots to further train its models. To prevent your chat data from being used for training, you can toggle off a specific setting within ChatGPT. A privacy policy for "Little Grass Shack Coaching" should clearly state how user data, if any, is handled in relation to AI tools and whether it contributes to AI model training.
It's important to note that "no AI platform is the same" regarding how it leverages insights from user data. Different services like Google's Bard or Anthropic's Claude have their own rules. Similarly, platforms like Chatbase claim to use the OpenAI API and ensure that your data is not used for training purposes.
Handling of Uploaded Knowledge and Proprietary Data
When creating a Custom GPT, users can upload files (PDFs, text files, CSVs, documents) to its knowledge base. It is crucial to be careful not to include information you don't want public, as these files may be available for users to access.
There's a significant concern about "Knowledge file exfiltration," where uploaded files could be vulnerable to unauthorized access. Files uploaded to a Custom GPT are saved under a specific path (/mnt/data) and can potentially be retrieved using prompt utilization. A privacy policy should explicitly address what type of data is collected or uploaded and how it is protected.
Organizations should review their files for sensitive information, such as personal information or intellectual property, before uploading them to a Custom GPT to avoid exposure.
Data Leakage via "Actions" (API Integrations)
Custom GPTs can be connected to third-party applications and databases via "Actions" and APIs. When these actions are used, data is sent to the third-party API.
ChatGPT currently has no mechanism to stop sending Personally Identifiable Information (PII) data to third-party APIs, meaning sensitive information could be leaked. Your privacy policy would need to disclose that data might be shared with third-party services when using AI-driven features that interact with external systems.
The OpenAPI schema, which defines how the GPT communicates with external APIs, can be inspected, revealing what data is sent to third parties.
The risk of "Indirect Prompt Injections" also exists, where responses from third-party APIs could subtly alter the GPT's behavior or narrative without the user's knowledge, potentially leading to misinformation.
Requirement for a Privacy Policy for Publicly Available GPTs
If "Little Grass Shack Coaching" were to develop and publish a Custom GPT, a "privacy URL" would need to be provided for it to be made publicly accessible. This implies a formal privacy policy is a prerequisite for public deployment.
Enterprise-Level Security and Compliance
For businesses deploying AI chatbots, "Security and Compliance" are major concerns, encompassing regulations like GDPR and HIPAA.
Comprehensive security strategies, including regular security audits, strong encryption methods, and transparent data usage policies, are crucial. A privacy policy needs to outline these measures to build trust.
Companies like CustomGPT.ai explicitly state they are "GDPR & SOC2 Compliant" and have their own "Privacy Policy" and "Cookie Policy". This suggests the level of detail and compliance expected in such policies.
In summary, while the sources don't provide a template, they strongly underscore the necessity of a robust privacy policy for any entity, including "Little Grass Shack Coaching," especially if it interacts with user data or employs AI tools. Such a policy should meticulously detail data collection, storage, usage, sharing with third parties (including AI providers and APIs), security measures, and compliance with relevant regulations.