Global Privacy Regulators Issue Joint Statement on AI-Generated Imagery and Privacy Risks
The increasing use of artificial intelligence (“AI”) tools to generate realistic images and videos raises growing legal and reputational risks for charities and not-for-profit organizations (“NFPs”), particularly where such content may depict identifiable individuals without their consent. In response to these concerns, a coalition of 61 global privacy regulators, including the Office of the Privacy Commissioner of Canada, issued a Joint Statement (the “Statement”) on February 23, 2026 addressing the misuse of AI-generated imagery and its impact on privacy.
The Statement highlights growing risks associated with widely accessible AI tools, particularly those integrated into social media platforms. These tools can be used to create non-consensual intimate images, defamatory content, and other harmful depictions involving real individuals. Regulators emphasized that such misuse could have serious consequences, especially for children and other vulnerable groups, including risks of cyberbullying and exploitation.
The Statement reminds organizations that the development and use of AI systems must comply with applicable privacy and data protection laws. It also notes that certain uses of AI-generated imagery – such as the creation of non-consensual intimate content – may constitute criminal offences in some jurisdictions.
To address these risks, regulators outlined several key expectations for organizations developing or using AI content generation tools. These include implementing safeguards to prevent misuse of personal information, ensuring transparency about how AI systems function and are used, and providing accessible processes for individuals to request the removal of harmful content. Emphasis was on the need for enhanced protections for children. More broadly, regulators emphasized that organizations should ensure that technological advancement does not come at the expense of privacy, dignity, safety, and other fundamental rights, particularly for the most vulnerable of society.
The Statement also signals increased coordination among regulators globally, including information sharing and potential enforcement activity, as part of a broader effort to address the harms associated with AI-generated content.
For charities and NFPs, this development highlights the need to exercise caution when using AI-generated images or videos, particularly where real individuals may be depicted. Organizations should avoid using AI tools to create content that could identify individuals without consent and should ensure that any third-party platforms they use include appropriate safeguards. It would also be prudent to review internal policies on AI use, ensure staff are aware of privacy risks, and implement clear processes for responding to complaints or requests to remove content.
Canada’s Next AI Strategy: Key Themes from Public Consultation
Following the launch of the AI Strategy Task Force (as covered in the October 2025 Charity & NFP Law Update), Innovation, Science and Economic Development Canada (“ISED”) has released a Summary of Inputs from its public consultation on Canada’s next artificial intelligence (“AI”) strategy, providing insight into how the federal government may approach AI policy and regulation in the coming years. The consultation, conducted in October 2025, drew over 11,300 responses from individuals, businesses, academics, and civil society, making it the largest public consultation in ISED’s history. The summary, titled “Engagements on Canada’s next AI Strategy” was released February 5, 2026 (the “Summary”).
For charities and not-for-profit organizations (“NFPs”), the Summary highlights both opportunities and emerging risks associated with AI adoption, particularly in areas such as governance, data use, and public trust.
A central theme was balancing innovation with responsible governance. Participants urged alignment with core values such as privacy, fairness, sustainability and inclusivity, supporting risk-based regulation and independent oversight. Public trust remains a key concern, with respondents highlighting risks related to bias, privacy breaches, misinformation, and job displacement, calling for greater transparency in how AI systems are developed and deployed. For charities and NFPs, this may mean increased scrutiny of AI use in fundraising and service delivery.
Regarding data governance and intellectual property (“IP”) protection, participants expressed concern about the dominance of foreign entities, and the use of copyrighted or creative works in AI systems without owner consent. Stronger IP protections, clearer consent requirements, and policies could help Canadian organizations retain control over their data. These issues are relevant for charities and NFPs that create original content that could be used in AI training systems.
The Summary also highlighted the need for increased AI literacy and skills development. Respondents supported a dual approach that combines broad digital literacy for the general public with specialized training for technical roles. This includes integrating AI education into school curricula, expanding lifelong learning opportunities, and ensuring equitable access to training. For the charitable sector, this may create both a need and an opportunity to invest in staff training and to develop programming that supports digital inclusion.
Infrastructure and technological sovereignty were also prominent concerns. Participants pointed to gaps in Canada’s computing capacity, data infrastructure, and connectivity, particularly in rural and underserved regions. Many advocated for a “sovereign” approach to AI infrastructure, including domestically controlled data centres and reduced reliance on foreign providers. Environmental impacts were also noted, with calls for sustainable approaches to energy use in AI systems.
In terms of AI adoption, respondents and Task Force experts stressed the importance of real-world applications that improve productivity and public services. At the same time, there was caution about premature deployment, particularly in sensitive sectors such as health care and public services. For charities and NFPs, this reflects the need to adopt AI thoughtfully, ensuring that efficiency gains do not come at the expense of human oversight or service quality.
The consultation and 32 Task Force reports revealed a broader tension between optimism and skepticism regarding AI. While many respondents highlighted the potential for economic growth and improved services, others warned of ethical, environmental, and social risks. Concerns were also raised about the underrepresentation of marginalized groups in AI development, which may lead to biased outcomes. Participants called for more inclusive approaches, including diverse participation in AI design and governance.
Overall, the Summary underscores that Canada’s forthcoming AI strategy will likely emphasize responsible innovation, regulatory clarity, and public trust. For charities and NFPs, this evolving policy landscape signals the importance of proactive engagement with AI governance issues, including data management, transparency, and ethical use. As the federal government moves toward releasing its updated strategy in 2026, organizations may wish to monitor developments closely and consider how their own use of AI aligns with emerging expectations and standards.