Large Language Models are trained on extensive datasets that often contain sensitive, human-generated information, raising significant concerns about privacy breaches. While certified unlearning approaches offer strong privacy guarantees, they rely on restrictive model assumptions that are not applicable to LLMs. As a result, various unlearning heuristics have been proposed, with the associated privacy risks assessed only empirically. The standard evaluation pipelines typically randomly select data for removal from the training set, apply unlearning techniques, and use membership inference attacks to compare the unlearned models against models retrained without the to-be-unlearned data. However, since every data point is subject to the right to be forgotten, unlearning should be considered in the worst-case scenario from the privacy perspective. Prior work shows that data outliers may exhibit higher memorization effects. Intuitively, they are harder to be unlearn and thus the privacy risk of unlearning them is underestimated in the current evaluation. In this paper, we leverage minority data to identify such a critical flaw in previously widely adopted evaluations. We substantiate this claim through carefully designed experiments, including unlearning canaries related to minority groups, inspired by privacy auditing literature. Using personally identifiable information as a representative minority identifier, we demonstrate that minority groups experience at least 20% more privacy leakage in most cases across six unlearning approaches, three MIAs, three benchmark datasets, and two LLMs of different scales. Given that the right to be forgotten should be upheld for every individual, we advocate for a more rigorous evaluation of LLM unlearning methods. Our minority-aware evaluation framework represents an initial step toward ensuring more equitable assessments of LLM unlearning efficacy.
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