Sustainable AI and personal data - lessons from the DPA report

03 Feb 2026
Sustainability Specialist
In the era of the fourth industrial revolution, our approach to technology is becoming a cornerstone of ESG strategy. We take an active part in consultations and studies on current, legislative and technological issues, and we were also a participant in the survey of the President of the Office for Personal Data Protection to see how Polish organizations are coping with the implementation of artificial intelligence. The conclusions of the „Strategic Report - Survey of the Needs of Organizations in the Use of Artificial Intelligence and Personal Data Protection” (January 2026) are clear: we stand at the threshold of a great transformation, but we lack solid foundations in the management and social areas.

How are Polish organizations implementing artificial intelligence? 

Data from the report show strong market polarization. While 17% organizations say they are using AI in their daily operations, as many as 43% entities still have not touched the technology. At MATERIALITY, we see this as a huge opportunity for digital sustainability. The area of digital security and data protection is subject to analysis and disclosure in sustainability reports. 

The Report says that AI is most often used in administrative automation (41.2%) and data analytics (31%). This is a positive trend, as AI technology, properly implemented, saves resources and optimizes processes. However, the real challenge is not the technology itself, but awareness of the risks it brings. 

Data protection awareness gap - the biggest ESG risk 

The most disturbing finding of the report is the systemic „awareness gap.” As many as 58.5% of the surveyed organizations believe that the use of artificial intelligence does not involve the processing of personal data, or cannot assess it. 

From an ESG perspective, personal data is social capital entrusted to us by stakeholders, customers and end users. Ignoring the link between algorithms and privacy strikes directly at the pillar of governance. Responsible data management is not only a matter of avoiding penalties, but more importantly of building trust, which is the most valuable currency in modern business. 

Barriers to AI implementation: from regulation to ethics 

What's holding us back from fully realizing AI's potential? The UODO report points to organizational and regulatory barriers that dominate the technical problems. Topping the list is the lack of adequate data to train the models, and complex regulations (AI Act and RODO). 

Many organizations feel left behind. 95.9% respondents rate themselves as unprepared or unsure of how to apply regulations. This is a signal to sustainability professionals: our role is to translate these complex relationships into the language of benefits and ethical standards. Digital sustainability is a requirement that requires us to create a clear operational framework before algorithms take the reins in key processes. 

AI Compliance Starter - the path to responsible governance 

The answer to the diagnosed shortcomings is the „AI Compliance Starter” package recommended by the DPA. It's a set of tools - from model risk analyses (DPIAs) to checklists for administrators - designed to help organizations safely enter the world of AI. At MATERIALITY, we support such initiatives because we believe in transparency. 

Creating a repository of best practices and decision-making maps is nothing more than introducing the principles of the circular economy into knowledge management. Information must circulate in a secure, transparent and useful manner. Only when our „electrical system” (i.e., corporate governance and data protection) is in working order will we be able to fully enjoy modern equipment in the form of artificial intelligence. 

Summary: The future of AI in ESG strategies 

The UODO's January 2026 report is an important benchmark for us. It shows that the road to responsible artificial intelligence in Poland is still long, but the direction has been set. At MATERIALITY, we will actively support the building of this awareness. Let's remember: technology is just a tool. Let's use it wisely.  

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