Do LLMs Really Memorize Personally Identifiable Information? Revisiting PII Leakage with a Cue-Controlled Memorization Framework
Xiaoyu Luo, Yiyi Chen, Qiongxiu Li Aalborg University, Johannes Bjerva Aalborg University
Large Language Models (LLMs) have been reported to “leak” Personally Identifiable Information (PII), with successful PII reconstruction often interpreted as evidence of memorization. We propose a principled revision of memorization evaluation for LLMs, arguing that PII leakage should be evaluated under low lexical cue conditions, where target PII cannot be reconstructed through prompt-induced generalization or pattern completion. We formalize Cue-Resistant Memorization (CRM) as a cue-controlled evaluation framework and a necessary condition for valid memorization evaluation, explicitly conditioning on prompt-target overlap cues. Using CRM, we conduct a large-scale multilingual re-evaluation of PII leakage across 32 languages and multiple memorization paradigms. Revisiting reconstruction-based settings, including verbatim prefix-suffix completion and associative reconstruction, we find that their apparent effectiveness is driven primarily by direct surface-form cues rather than by true memorization. When such cues are controlled for, reconstruction success diminishes substantially. We further examine cue-free generation and membership inference, both of which exhibit extremely low true positive rates. Overall, our results suggest that previously reported PII leakage is better explained by cue-driven behavior than by genuine memorization, highlighting the importance of cue-controlled evaluation for reliably quantifying privacy-relevant memorization in LLMs.
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Proceedings of the 64th Annual Meeting of the Association for Computational Linguistics (Volume 1: Long Papers) · 2026 · 正式发表