提出无需模型访问的隐私审计框架，区分真实泄露与偶然生成。

The rapid adoption of generative AI and Large Language Models (LLMs) has spurred interest in synthetic data as a privacy-preserving alternative to sensitive real-world datasets. However, generating high-utility synthetic data often carries the risk of memorizing and regurgitating private information from the training corpus. In this work, we present a customizable empirical auditing framework designed to detect and explain such data disclosures. Our framework introduces a mechanism to distinguish between "true disclosures"-where the system directly reproduces a user's information-and "phantom disclosures''-where the system incidentally generates a user's data. By partitioning input data into training and holdout sets and applying rigorous statistical hypothesis testing, we determine if observed disclosures are consistent with strict privacy baselines, such as zero-learning or specific Differential Privacy (DP) bounds. Crucially, this approach requires no model access, no canary insertion, and no reference model training -only the synthetic output and a held-out control set. We demonstrate that this framework effectively functions as a membership inference attack, providing empirical lower bounds on privacy leakage that are tighter than prior data-based auditing methods. Our approach is model-agnostic, applies to any synthetic data generation mechanism, and requires orders of magnitude fewer computational resources than shadow-model or canary-based alternatives.