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Can We Trust AI to Govern AI? Benchmarking LLM Performance on Privacy and AI Governance Exams

Created by
  • Haebom

Author

Zane Witherspoon, Thet Mon Aye, YingYing Hao

Outline

This paper presents the results of a study evaluating the performance of ten leading open and closed large-scale language models (LLMs) on the International Association of Privacy Professionals (IAPP) CIPP/US, CIPM, CIPT, and AIGP certification exams. In closed-ended exams against models from OpenAI, Anthropic, Google DeepMind, Meta, and DeepSeek, state-of-the-art models such as Gemini 2.5 Pro and OpenAI's GPT-5 surpassed the passing standards of human experts, demonstrating significant expertise in privacy law, technical controls, and AI governance. This study provides practical insights into assessing the readiness of AI tools for critical data governance roles, provides an overview for professionals navigating the intersection of AI development and regulatory risk, and establishes machine benchmarks based on human-centered assessments.

Takeaways, Limitations

Takeaways:
A cutting-edge LLM demonstrates that it achieves performance above human experts on professional certification exams related to privacy.
The LLM presents the potential for supporting privacy compliance, program management, and AI governance.
Providing practical insights into assessing the readiness of AI tools for data governance roles.
Presenting the strengths of LLM and the limitations of specific areas simultaneously to suggest future research and development directions.
Limitations:
Because the study results are limited to a specific LLM and exam, generalizability may be limited.
Since this is an evaluation result from a closed test environment, there is a possibility that performance differences may occur when applied to an actual work environment.
Because the scope of the exam is limited to the IAPP certification exam, further research is needed to assess other areas of expertise in the LLM.
Lack of consideration of the reliability and ethical issues of LLM's responses.
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