[bryant]

Looks very relevant. If the same service (e.g same instance of the model, or even different instances of the same model) is provided to more than one client, I'd guess a prosecutor might reach for it.

Easiest but most costly way this could be avoided is by creating new models for each client using the client's own specific data and keeping the data and models fully isolated for each client.

If derivative insights are gathered across all models, it'd have to be one-way informing e.g business decisions for the overall company rather than informing how the models themselves operate.

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edit: "We pivoted to a 'global model' that used data across countries to significantly reduce the amount of data required in any one country."

This might paint a bullseye on their back, but I'm a security and risk person, not a lawyer.