Governance

Data trust

Mechanism for trusted sharing and reuse of public-sector data.

How the laws define this

Both instruments agree that a data trust is a legal or governance structure providing controlled access, custodianship, and stewardship of datasets for the public benefit while balancing data reuse with privacy protections. Under both frameworks, these arrangements establish rules, responsibilities, and safeguards to enable secure data sharing and accountability. The main point of divergence concerns the origin of the managed data and its specific application. The Policy for the Development of Artificial Intelligence in Poland from 2020 explicitly restricts the construct to public-sector data and emphasizes its reuse specifically for artificial intelligence development alongside public-interest applications. Conversely, Toward an AI Strategy in Mexico frames the scope more broadly to encompass datasets shared across various actors to facilitate interoperable, secure sharing for general public benefit, without confining the data source to the public sector or limiting its role explicitly to artificial intelligence.

Synthesised from the 2 statutory definitions below. Each one is quoted in full, with its source.

How jurisdictions differ

What is distinctive in each definition, binding law in force first.

Jurisdiction	Instrument	Status	What is distinctive
Poland	Policy for the Development of Artificial Intelligence in Poland from 2020	In Force	Emphasizes an organizational and legal construct for stewarding data specifically to enable AI development and public-interest applications, with explicit governance, access conditions, responsibilities, and ethical safeguards.
Mexico	Toward an AI Strategy in Mexico: Harnessing the AI Revolution	Adopted	Focuses on a governance arrangement or legal structure for custodianship and shared stewardship, highlighting interoperable and secure data sharing across actors.

What it triggers

In the Toward an AI Strategy in Mexico report, it proposes data trusts as part of 21 actionable recommendations to harness AI for economic and social development.source

Definitions (2)

An organizational and legal construct that stewards public‑sector data to enable controlled access and reuse for AI development and public‑interest applications, defining governance, access conditions, responsibilities and safeguards (including privacy and ethical constraints). It is intended to balance data utility with protection and accountability by establishing agreed rules and trusteeship for datasets.

Policy for the Development of Artificial Intelligence in Poland from 2020 (Polityka dla rozwoju sztucznej inteligencji w Polsce od roku 2020) – Polityka rozwoju sztucznej inteligencji w Polsce na lata 2019–2027Definition 1 of 2

A governance arrangement or legal structure that enables custodianship, controlled access and shared stewardship of datasets for public benefit, balancing reuse and privacy while enabling interoperable, secure data sharing across actors.

Hacia una Estrategia de IA en México: Aprovechando la Revolución de la IA (Toward an AI Strategy in Mexico)Definition 2 of 2

Not to be confused with

data trustee

Data trustee refers specifically to a neutral intermediary managing rights, consent, and access, while data trust is the broader organizational or legal construct encompassing such roles.

Trust/security

Trust/security covers privacy, data governance, robustness, and cybersecurity as general concepts, whereas data trust is a specific stewardship mechanism for controlled data access and reuse.

Questions and answers

What is distinctive about Poland's data trust definition?

Poland's definition frames data trust as an organizational and legal construct that stewards public-sector data specifically for AI development and public-interest applications. It details governance, access conditions, responsibilities, and safeguards like privacy and ethics. This balances data utility with protection through agreed rules and trusteeship.

How does Mexico's data trust differ from others?

Mexico's definition presents data trust as a governance arrangement or legal structure for custodianship and shared stewardship of datasets. It emphasizes balancing reuse and privacy while enabling interoperable, secure data sharing across actors.