The Observation

There is a difference between a driver who can recite the sporting regulations and one who reads the race correctly in real time under pressure. Most AI literacy programmes are training the former. A driver can be flawless in the simulator and still lock up under pressure on lap one.

Everyone agrees employees need AI skills. Nobody can define or measure what that means. We went through exactly this cycle with digital literacy fifteen years ago and most organisations still cannot meaningfully assess it. The window for establishing credible AI literacy frameworks is relatively narrow, perhaps 12 to 18 months, before the market defaults to checkbox awareness modules bolted onto existing LMS platforms, which will tick the training box without building genuine competence.

What This Means for Data Privacy

Article 5(2) accountability requires organisations to demonstrate compliance, not just deliver training. For AI, that means being able to evidence that employees know how to use these tools responsibly, not just that they completed a module.

It may be worth considering whether your awareness programme currently defines observable behaviours for responsible AI use, checking AI output before sharing externally, or not inputting personal data into unapproved tools. Completion certificates measure whether someone knows the regulations. Behavioural indicators measure whether they have got race craft. We find that organisations which tie AI literacy to measurable behaviours rather than completion certificates are better placed to demonstrate accountability. If those behavioural definitions do not exist yet, this is a gap worth closing before AI use scales further.