b'using GAI tools to process their data and simply obtaining a clients consent cannot be used as a substitute for the due diligence weve outlined throughout this Guide. The non-exclusive considerations identified in Comment [18] to Illinois Rule of Professional Conduct 1.6 remain relevant when evaluating the use of GAI tools: 1. The sensitivity of the information;2. the likelihood of disclosure if additional safeguards are not employed;3. the cost of employing additional safeguards;4. the difficulty of implementing the safeguards; and5. the extent to which the safeguards adversely affect the lawyers ability to represent clients (e.g., bymaking a device or important piece of software excessively difficult to use).Although Comment [18] predates modern GAI tools, lawyers can still use its technology-neutral balancing test to determine what safeguards are appropriate when using GAI tools, including providing notice and opt-out rights, or, in appropriate cases, seeking informed client consent.The table below shows one example of how a lawyer might use the GAI categories we reviewed in Step 3 above (public, consumer, business, and enterprise) to determine how best to manage client communications for different levels of information sensitivity. They are not endorsements and do not constitute legal advice. Inthisexample,thelawyerhasdeterminedthatGeneralInformation(whichwedefinedinStep1as Table 3: Relationship between data classification, GAI tool classification, and client communication strategyinformationthatisentirelyunrelatedtoanymatterthelawyerhasundertakenprofessionallyandis otherwisenotsubjecttoanyconfidentialityprotections)doesnotrequireanyclientcommunication regardless of the level of safeguards incorporated into the GAI tool. Despite the fact that no client information is being processed, the lawyer should still exercise caution when entering information into a public GAI tool due to the absence of privacy and security safeguards. With respect to De-Identified Information (which we defined in Step 1 as information that relates to the representation of a client, but for which there is no reasonable likelihood that it could be used to ascertain the identity of the client or matter), the lawyer has determined that clients should receive reasonable notice Page | 19'