Access Now submission to the EU consultation on the AI whitepaper

Check out the submission from myself and Fanny Hidvégi from Access Now to the European Commission’s ‘White Paper on Artificial Intelligence – A European Approach.’ As well as contributing via the online consultation form, we have put together an additional document outlining our six key recommendations:

  1. We must not promote the indiscriminate uptake of artificial intelligence. The uptake of any technology, particularly in the public sector, should not be a standalone goal and it is not of value in itself.
  2. Implement a rights-based approach and mandatory human rights impact assessments. We oppose a binary high/low risk approach. All AI applications must respect human rights. We call for mandatory human rights impact assessments for all AI/ADM.
  3. No safeguard or remedy could make indiscriminate biometric surveillance or predictive policing acceptable, justified or compatible with human rights. Ban applications that are incompatible with fundamental rights such as biometric technologies that enable mass surveillance.
  4. Establish national centres of AI expertise to help existing regulators (recommendation in collaboration with AlgorithmWatch). Scope: monitor, assess, conduct research, report on, coordinate but no direct enforcement or complaint handling.
  5. Establish public registers for AI/ADM systems (recommendation in collaboration with AlgorithmWatch)
  6. Enforce high scientific standards

“The EU has an obligation to respect and promote human rights. The European Commission should put human rights at the center of artificial intelligence policies with legislation for mandatory human rights impact assessments and the creation of public registers.”, said Fanny Hidvegi, Europe Policy Manager at Access Now.

“Although strong regulation and safeguards can mitigate certain harms, we need to accept that certain uses of technology, such as biometric recognition systems that enable mass surveillance, are so incompatible with the protection of fundamental rights that these systems simply should not be used,” said Daniel Leufer, Mozilla Fellow at Access Now.

You can find the summary of our recommendations in this blog post here:    

Our consultation response is here:

And our additional recommendations: