Your Shadow Eval Set Is a Compliance Time-Bomb
The most dangerous data store in your AI stack is the one nobody designed. It started with a Slack message during a sprint: "Real users are the only thing that catches real bugs — let's tap a percentage of production traffic into the eval pipeline so we can replay it nightly." Six engineers thumbs-upped the message. Nine months later, the bucket holds 4.3 million traces, an eval job pages the on-call when failure rates rise, and the failure cases are emailed verbatim to a Slack channel where forty people can read them. The traces include email addresses, internal company names, partial credit-card digits, employee phone numbers, and customer support transcripts where users explained why they were upset.
Nobody mapped the data flow. No DPIA covered it. The privacy review last quarter looked at the model vendor's API; it didn't look at your eval job. And then a data-subject deletion request arrives, and the team discovers that "delete this user's data everywhere" is a sentence that no longer maps to anything they can actually do.
